- 22 - showed net profits (viz., $99,000 net profit from art sales and $7,372 net profit from Psychological Testing Services), and not the Schedules C that showed losses (viz., $2,925 loss from commodities and other investments and $44,375 loss from New Life Center). Consequently, petitioner deducted in his 1989 return the entire $20,000 that he contributed to the SEP. That deduc- tion exceeded (by $5,075) 25 percent of the aggregate amount (viz., $59,702) of the results shown in the various Schedules C of that return that petitioner reported as his "Business income" (business income) on page 1, line 12 of that return. With respect to the $30,000 contribution that petitioner made to the SEP for 1990, petitioner deducted $16,912 in his return for that year. That deduction equaled 25 percent of the aggregate amount (viz., $67,648) of the results shown in the various Schedules C of that return that petitioner reported as his business income for 1990. With respect to the $26,000 contribution that petitioner made to the SEP for 1991, petitioner deducted that entire amount in his return for that year. That deduction equaled 24.91 percent of the amount (viz., $104,371) shown in Schedule C of that return that petitioner reported as his business income for 1991. At the time that Mr. McVeigh prepared petitioner's returns for the years at issue, Mr. McVeigh did not know of any adverse tax consequences that might result if petitioner's retirement plan contribution for each such year exceeded the amount allow-Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
Last modified: May 25, 2011