- 2 - Respondent determined deficiencies in petitioners' 1988, 1989, and 1990 Federal income taxes in the amounts of $160, $3,624, and $3,343, respectively. After concessions,2 the issue for decision is whether rental income derived from certain agricultural leases constitutes net earnings from self- employment. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the exhibits attached thereto are incorporated herein by this reference. During the years in issue, petitioners were husband and wife and filed joint Federal income tax returns. At the time the petition was filed, petitioners resided in Gould, Arkansas. References to petitioner are to Lee Mizell. Petitioner listed his occupation as "farmer" on his 1988, 1989, and 1990 Federal income tax returns. He has been engaged in the production of agricultural commodities as a farmer most of his adult life. Over a period of years, petitioner purchased agricultural land in Lincoln County, Arkansas. Specifically, petitioner purchased 55 acres in 1978, 50 acres in 1979, 500 acres in 1986, and 35 acres in 1988. Additionally, petitioner leased 2Petitioners conceded the correctness of adjustments for auto depreciation in the amounts of $10,310, $496, and $298 for the years 1988, 1989, and 1990, respectively.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011