Woody F. Lemons - Page 65

                                       - 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

Last modified: May 25, 2011