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MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge: This case was heard
pursuant to the provisions of section 7443A(b)(3) and Rules 180,
181, and 182.2
Respondent determined a deficiency in the amount of $1,522
in petitioner's Federal income tax for the taxable year 1990.3
The issues for decision are:
1. Whether petitioner and her husband, Jacob B. Neiman,
failed to report income received by Jacob B. Neiman; and
2. Whether said income is subject to self-employment tax.4
At the time of filing the petition herein, petitioner
resided at Cincinnati, Ohio. While no formal stipulation was
filed, the parties agreed to a number of exhibits which were made
part of this record. There was no testimony, and, accordingly,
2 All section references are to the Internal Revenue Code
in effect for the tax year at issue. All Rule references are to
the Tax Court Rules of Practice and Procedure.
3 Jacob B. Neiman died in Mar. 1993, prior to the filing of
the petition herein. A notice of deficiency was issued to
petitioner Norma Neiman and Jacob B. Neiman, deceased. The
petition was captioned in both names. By order dated Apr. 6,
1994, respondent's motion to dismiss for lack of jurisdiction as
to the estate of Jacob B. Neiman, deceased, and to change caption
was granted since Norma Neiman failed to establish that she had
authority to represent her deceased husband. The caption of this
case was changed to read "Norma Neiman, Petitioner, v.
Commissioner of Internal Revenue, Respondent".
4 Issues of omitted interest and dividend income were not
contested by petitioner.
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