Paul B. and Jane C. Ding - Page 2

                                        - 2 -                                         

          Respondent determined deficiencies in petitioners' 1991 and 1992            
          Federal income taxes in the amounts of $3,562 and $6,159,                   
          respectively.                                                               
               The deficiencies are attributable primarily to respondent's            
          determinations that petitioners understated Paul B. Ding's self-            
          employment tax liabilities for the years in issue.  The issues              
          for decision are:  (1) Whether pass-through items from certain S            
          corporations are taken into account in computing Paul B. Ding's             
          self-employment income for each year; and (2) whether a carryover           
          loss from 1991 can be taken into account in computing Paul B.               
          Ding's self-employment income for 1992.                                     
                                  FINDINGS OF FACT                                    
              Some of the facts have been stipulated, and they are so                
          found.  Petitioners filed joint Federal income tax returns for              
          the years 1991 and 1992.  At the time the petition was filed in             
          this case petitioners resided in St. Louis, Missouri.  References           
          to petitioner are to Paul B. Ding.                                          
               During the years in issue, petitioners were shareholders in,           
          and petitioner was president of, three corporations (the S                  
          corporations), each of which had an election under section                  
          1362(a) in effect for one or both years.  Each corporation was              
          organized to take advantage of the limited liability                        
          characteristic of that form of business.  Petitioners owned 100             
          percent of the stock of one of the S corporations and at least 50           





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  Next

Last modified: May 25, 2011