Carla J. Zimmerman - Page 7

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          credit of $474 was claimed.  The Form W-2 attached to the 1988              
          return reflects $2,000 paid to Mr. Zimmerman by Staff Leasing,              
          Inc.  On their Form 1040 for 1989, the only income item reported            
          was $808.37 in net Schedule C business income; an earned income             
          credit of $114 was claimed.  Petitioner signed the returns but              
          claims that she did not look at the returns when she signed them.           
               After examination of the returns, respondent increased the             
          Zimmermans' income as follows:                                              

          Item                     Taxable Year 1988     Taxable Year 1989            
          Wages                    $12,609               $2,799                       
          Interest income          115                   160                          
          Dividend income          31                    ---                          
          Schedule C income        27,613                8,273                        
          Schedule C expenses           11,125               43,980                   
          Totals                   $51,493               $55,212                      
          Respondent increased self-employment tax by $5,223 and $6,250,              
          and disallowed (recaptured) the earned income credit of $474 and            
          $114, for 1988 and 1989, respectively.                                      
               The omitted wages, interest income, and dividend income are            
          items attributable to petitioner; the increases in Schedule C               
          income and the disallowance of portions of the Schedule C                   
          expenses are items attributable to Mr. Zimmerman.  Petitioner               
          concedes that she failed to report her W-2 wages from Martin                
          Marietta, her dividends, and her interest income in the amounts             
          as determined by respondent.  Petitioner seeks to be relieved of            
          liability as an innocent spouse as to the Schedule C items                  
          attributable to Mr. Zimmerman.                                              




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