Woody F. Lemons - Page 32

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             his or her return and reported self-employment tax of                    
             $2,334.87.  It appears that the self-employment tax                      
             computed by each petitioner for 1987 is based upon one-                  
             half of the net earnings from three businesses reported                  
             on Schedules C and a net loss from one or more farm                      
             partnerships.  A summary of the self-employment tax                      
             computed by each petitioner for 1987 is as follows:                      
                                                                                     
                                                            1987                      
                 Self-Employment Tax              Total     1/2 Share                 
                 Schedule C, Production-Oil & Gas$61.30      $30.65                    
                 Schedule C, Financial Adviser  40,706.81   20,353.41                 
                 and investments                                                      
                 Schedule C, Pilot Lessons-     (286.75)    (143.38)                  
                 Charter Flights                                                      
                 Net Profit from Schedule C     40,481.36   20,240.68                 
                 & Schedule K-1                                                       
                 Net Farm Profit or Loss from                                         
                 Schedule F & Farm Partnerships (2,516.00)  (1,258.00)                
                                               37,965.36   18,982.68                 
                 Rate                           0.123       0.123                     
                 Self-employment tax            4,669.74    2,334.87                  

                 For 1988, each petitioner filed a Schedule SE, Social                
             Security Self-Employment Tax, with his or her return and                 
             reported self-employment tax of $1,100.47.  It appears                   
             that the self-employment tax computed by each petitioner                 
             is based upon one-half of the net earnings from four                     
             businesses reported on Schedules C, the income from two                  
             joint ventures reported as miscellaneous income, and a net               







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