- 3 - 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).Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011