- 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).
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