- 2 - and all Rule references are to the Tax Court Rules of Practice and Procedure. After concessions,1 the issues to be decided are as follows: 1. Whether petitioners are entitled to deduct certain expenses related to petitioner's medical practice that were not claimed on petitioners' return; 2. whether petitioners are liable for the self-employment tax pursuant to section 1401(b) in the amount of $1,240; 3. whether petitioners are entitled to a rental loss deduction in the amount of $23,576; and 4. whether petitioners are entitled to itemized deductions in the amount of $1,372. FINDINGS OF FACT Some of the facts have been stipulated for trial pursuant to Rule 91. The parties' stipulations of fact are incorporated herein by reference and are found as facts in the instant case. 1 In the notice of deficiency, respondent determined that petitioners had unreported income from certain sources in the amount of $60,552. At the calendar call in the instant case, petitioner Mangalore G. Krishna stated, "We don't have any objections to the amounts in question as far as the income." Accordingly, we consider the unreported income amounts to have been conceded. Additionally, in the notice of deficiency, respondent determined that petitioners were liable for an addition to tax pursuant to sec. 6651(a)(1) for failure to file timely their 1991 income tax return. At trial, petitioner Sita G. Krishna conceded the sec. 6651(a)(1) addition to tax. Respondent conceded that petitioners are entitled to a withholding tax credit in the amount of $2,496, which was not included in the notice of deficiency.Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011