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loss from one or more farm partnerships. A summary of the
self-employment tax computed by each petitioner for 1988 is
as follows:
1988
Schedule C, Production-Oil & Gas $26.15
Schedule C, Financial Adviser & Investments 5,789.01
Schedule C, Pilot Lessons-Charter Flights (531.25)
Schedule C, Coin Dealer (85.77)
Joint Venture--Middleton 750.00
Joint Venture--Tex-Mart 4,211.00
Net Profit from Schedule C & Schedule K-1 10,159.14
Net Farm Profit or Loss from Schedule F
& Farm Partnerships (1,707.00)
8,452.14
Rate 0.1302
Self-employment tax 1,100.47
The notice of deficiency issued to petitioner
determined that his self-employment taxes for 1987 and 1988
are $4,465 and $4,935, respectively. The only explanation
of this adjustment in the notice of deficiency is the
following: "We have adjusted your self-employment tax due
to a change in your net profit from this self-employment."
The notice of deficiency issued to Mrs. Lemons did not
adjust the self-employment tax that she reported.
OPINION
Moonlight Beach Club Issue
The principal issue in these cases involves the
characterization of the loss petitioner realized in 1986
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