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records and information concerning deposits to the bank
accounts controlled by the taxpayer. The taxpayer
received gross income in the amounts of $ 1,282,614.00
and $ 515,204.00 rather than gross income from con-
tracting of $ 465,400.00 and $ 195,300.00 as reported
on the returns for the tax years 1989 and 1990 respec-
tively. It is further determined that the gross income
is self-employment income and thus subject to the self-
employment tax for the tax years 1989 and 1990.
OPINION
Before the trial herein had commenced but after the Court
had received and reviewed the document entitled "Stipulation of
Facts" and the exhibits attached thereto that the parties had
filed with the Court, the Court expressed its concern to the
parties about whether the record was clear as to (1) the conces-
sions, if any, made by the parties after the notice was issued
and (2) the amounts of the deposits that remained in dispute as
of the commencement of trial. The Court directed the parties to
supplement their stipulation of facts in order to clarify those
matters, and the parties filed a document entitled "Supplemental
Stipulation of Facts". (We shall refer to both the stipulation
of facts and the supplemental stipulation of facts as stipula-
tions.)
Upon review of the entire record in this case, we have found
certain errors in the stipulations and the briefs as to the
amounts of deposits into petitioners' accounts during 1989 and
1990 that remain in dispute. Consequently, we are not bound by
those errors in the stipulations, see Cal-Maine Foods, Inc. v.
Commissioner, 93 T.C. 181, 195 (1989), and in the briefs.
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