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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.
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