- 15 - renewal commissions in 1990, are not subject to self-employment tax. In the notice of deficiency respondent determined that the amounts Mr. Lencke received as residual premiums and in lieu of renewal commissions constitute income from self-employment within the meaning of section 1401 and, therefore, were subject to self- employment tax. Accuracy-Related Penalties Petitioners' Federal income tax returns for 1990, 1991, and 1992 were prepared by an attorney. Petitioners reported a tax liability of only $392 on their 1990 Federal income tax return. They failed to report net income received in lieu of renewal commissions for 1990. Their tax liability was substantially understated for that year. Petitioners claimed depreciation deductions on the Schedule C attached to their 1991 and 1992 Federal income tax returns for several items for which they have conceded they were not entitled to depreciation deductions. The items for which petitioners claimed depreciation deductions included a boat, lawn mower, and sprinkler, which were personal assets. They failed to maintain or present adequate substantiation to support some deductions claimed on their tax returns for 1991 and 1992. Respondent determined in the notice of deficiency that petitioners are liable for accuracy-related penalties underPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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