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apparently paid the amounts reflected on the returns as filed.3
On January 28, 1993, respondent selected petitioners'
returns for audit. Income from numerous Forms 1099 had been
omitted from the returns, particularly the return for the taxable
year 1991. As a result of the audit, the notice of deficiency
increased (decreased) petitioners' income by the following
amounts:
Item 1990 1991
Schedule C $16,034 $63,502
Interest income 17
Self-Employment tax (1,907)
Itemized deductions 113
Total adjustments $16,034 $61,725
Respondent also determined additional self-employment tax of
$4,222 for the taxable year 1991. Petitioner filed a petition in
this Court challenging the deficiencies, additions to tax, and
penalties determined in the notice of deficiency.
Shortly before trial petitioners stipulated and agreed to
the following items of unreported income. In the taxable year
1990, petitioners received the following income which was omitted
from their tax return for that year:
3The record does not disclose how much tax and interest
petitioners in fact paid or when they made such payment. The
notice of deficiency indicates that $15,646 and $408 for the
taxable year 1990 and 1991, respectively, were the total taxes
shown on the returns as filed. The $408 for 1991 was self-
employment tax.
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