Fred and Yvonne Michael - Page 9

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          self-employment taxes was a normal or usual incident of his                 
          business, as was the case in Commissioner v. Polk, supra.                   
               Past cases have required a stronger connection between the             
          adjustments creating the deficiency and the taxpayer's business.            
          See Polk v. Commissioner, 31 T.C. 412 (1958) (holding that                  
          adjustment arising from revaluations of taxpayer's inventory was            
          sufficiently connected and proximately related to taxpayer's                
          business); Standing v. Commissioner, 28 T.C. 789 (1957) (holding            
          that adjustment arising from accounting errors in taxpayer's                
          business was proximately related to taxpayer's business), affd.             
          259 F.2d 450 (4th Cir. 1958).  Therefore, we find that no part of           
          the deficiencies arising because of petitioner's failure to pay             
          self-employment taxes during the 1981 and 1982 taxable years was            
          attributable to petitioner's trade or business.                             
          Overstated Withholding by Petitioner                                        
               Petitioners claimed on their 1981 and 1982 Federal income              
          tax returns credits for withholding in the amounts of $11,060.84            
          and $12,601.25, respectively.  These amounts were never in fact             
          withheld or paid over to the Service.  A portion of the interest            
          expense deducted by petitioners on their 1991 Federal income tax            
          return represents interest on the unpaid tax liabilities arising            
          from the overstatement of credits for withholding.  That interest           
          was paid during the taxable year 1991.                                      
               Petitioners have failed to prove that the interest paid on             
          the tax liabilities resulting from their overstated withholding             




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