- 65 - we hereby sustain respondent's disallowance of the capital loss claimed by each petitioner in the amount of $4,441.36. Self-Employment Tax Issue As discussed above, the self-employment taxes reported by each petitioner and the amounts determined in the notices of deficiency are as follows: Woody F. Lemons, Docket No. 16562-90 Year Per Return Per Notice Adjustment 1986 -- -- -- 1987 $2,334.87 $4,465 $2,130.13 1988 1,100.47 4,935 3,834.53 Paula S. Lemons, Docket No. 16799-90 Year Per Return Per Notice Adjustment 1986 -- -- -- 1987 $2,334.87 $2,335 -- 1988 1,100.47 1,100 -- It is readily apparent that the notice of deficiency issued to Mrs. Lemons does not adjust the self-employment tax that she reported. On the other hand, the notice of deficiency issued to Mr. Lemons adjusts the self-employment tax that he reported for 1987 and 1988, but it does not explain the nature of the adjustments or their computation. The petition filed on Mr. Lemons' behalf does not take issue with these adjustments, and they were not raised at trial or in petitioners' opening brief.Page: Previous 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 Next
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