- 8 - Respondent's disallowance of home mortgage interest for 1989 will be sustained. Self-Employment Tax Section 1401 provides for a tax on the self-employment income of every individual. "Self-employment" income means the net earnings from self-employment derived by an individual. Sec. 1402(b). Net earnings from self-employment income is the gross income derived by an individual from any trade or business carried on by such individual, less the deductions allowed by this subtitle that are attributable to such trade or business. Sec. 1402(a). Petitioner had income from L&L in excess of the amount he reported on his 1988 Schedule C and Schedule SE. Accordingly, petitioner is liable for additional self-employment tax. Respondent's determination will be sustained on this issue. Additions to Tax and Penalty Sections 6653(a)(1) and 6662 Respondent determined that petitioners are liable for the section 6653(a)(1) addition to tax for 1988. Section 6653(a)(1) imposes an addition to tax equal to 5 percent of the underpayment if any part of the underpayment is due to negligence or an intentional disregard of rules or regulations. Respondent determined that petitioners are liable for the section 6662(a) penalty for 1989. Section 6662(a) imposes a penalty in an amount equal to 20 percent of the underpayment ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011