- 66 - 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 eitherPage: 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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