Charles A. Dennis and Alison M. Dennis - Page 16

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          that any increase in the self-employment tax causes a                       
          corresponding increase in the deduction for taxes paid on self-             
          employment income.  Sec. 164(f).                                            
          Additions to Tax                                                            
               Respondent determined that petitioners were negligent or               
          intentionally disregarded the rules or regulations in filing                
          their 1988 Federal income tax return under section 6653(a) and              
          their 1989 through 1991 Federal income tax returns under section            
          6662.  Petitioners do not deny that they were negligent or                  
          intentionally disregarded the rules or regulations, but instead             
          insist that there was no deficiency.  Petitioners offered no                
          evidence which would disprove respondent's determination to the             
          extent we have sustained respondent herein.  To the extent of the           
          deficiencies decided by this opinion, the additions to tax and              
          penalties for the tax years will apply.                                     
                                             Decision will be entered                 
                                        under Rule 155.                               

















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