Woody F. Lemons - Page 66

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                  Respondent's opening brief states as follows:                       

                       Also, there are two additional adjustments.                    
                  In the notice of deficiency issued to petitioner                    
                  in Docket No. 16562-90 [Mr. Lemons], respondent                     
                  did not adjust the self employment tax for the                      
                  1987 taxable year.  Respondent has recently                         
                  discovered that the correct amount of such tax                      
                  is $3,911 instead of $2,335.  Also, the adjust-                     
                  ment to the self employment tax for taxable year                    
                  1987 of petitioner in Docket No. 16799-90                           
                  [Mrs. Lemons] is also incorrect.  The amount                        
                  should be increased from the notice of deficiency                   
                  amount of $2,335.00 to $4,465.00.  Both of these                    
                  adjustments, because they are computational and                     
                  unrelated to the other adjustments in the                           
                  notices, should be addressed at the conclusion                      
                  of this matter under T.C. Rule 155.                                 

             Contrary to the above, the notice of deficiency issued to                
             Mr. Lemons, petitioner in docket No. 16562-90, does adjust               
             the self-employment tax reported by Mr. Lemons for 1987,                 
             and the notice of deficiency issued to Mrs. Lemons,                      


             petitioner in docket No. 16799-90, made no adjustment to                 
             the self-employment tax reported by Mrs. Lemons for 1987.                
                  Petitioners' reply brief contains the following                     
             statement in response to respondent:                                     

                       Respondent states that there are two                           
                  additional adjustments which were not made in the                   
                  Notice of Deficiency relating to self employment                    
                  tax for 1987 and that these adjustments should be                   
                  addressed in the Rule 155 computation.  Neither                     
                  of these adjustments was made in the Notice of                      
                  Deficiency, neither was mentioned in either                         






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