Gregory Summers and Justine Summers - Page 3

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          petitioners did not allege error with respect to this                       
          determination.                                                              
               The stipulation provides:                                              
                    THE PARTIES HEREBY stipulate to the following                     
               terms of settlement for all of the issues in the                       
               above-captioned case.  This stipulation disposes of all                
               the issues related to petitioners’ tax liability for                   
               the 1984 and 1985 tax years. * * * The parties                         
               stipulate to the following adjustments as reflected in                 
               the statutory notice of deficiency.                                    
               *    *       *      *       *         *      *                         
                    2.  Petitioners are not required to report                        
               Schedule C gross receipts in the amounts of $65,907.00                 
               for 1984 and $44,834.00 for 1985.  Instead, petitioners                
               are required to report Schedule C gross receipts in the                
               amounts of $41,857.00 for 1984 and $33,198.00 for 1985.                
               The gross receipts in both 1984 and 1985 were derived                  
               from petitioner’s, Gregory Summers, accounting                         
               business.  The gross receipts for both 1984 and 1985                   
               are subject to self-employment tax.                                    
                    3.  Petitioners are not required to report                        
               Schedule E taxable income from Summers & Co, in the                    
               amounts of $100,812.00 for 1984 and $88,730.00 for                     
               1985.  Instead, petitioners are required to report                     
               Schedule E taxable income from Summers & Co. in the                    
               amounts of $81,015.00 for 1984 and $40,134.00 for 1985.                
               These adjustments are attributable to petitioners’                     
               distributive share of Summers & Co. partnership income.                
                    4.  Petitioners are entitled to deduct Schedule E                 
               partnership losses in the amounts of $4,254.00 for the                 
               taxable year 1984 and $474.00 for the taxable year                     
               1985, as stated in the statutory notice of deficiency.                 
               *    *       *      *       *         *      *                         
                    THE PARTIES AGREE to this stipulation of settled                  
               issues.                                                                

          1 (...continued)                                                            
          income that is subject to the self-employment tax for those                 
          years.  Sec. 1402(b).                                                       




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