Jane B. Oliver and Robert P. Oliver - Page 19

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          J. Peeples Trust and $3,212 from their J. Masters note.  Thus,              
          petitioners received a total of $17,952 interest income in 1990.            
               On their 1990 Federal income tax return, petitioners                   
          reported $15,1282 interest income, consisting of $345 from                  
          Sunburst Bank, $172 from Planters Bank & Trust Co., $11,339 from            
          J. Peeples Trust, and $3,212 from their J. Masters note.                    
               In the notice of deficiency, respondent increased                      
          petitioners' income by $2,824, stating that they received                   
          interest income of $17,952 in the taxable year 1990, rather than            
          $15,128 as reported on their 1990 return.                                   
          Self-Employment Taxes                                                       
               Petitioners reported self-employment tax on their Federal              
          income tax returns for 1990 and 1991 in the amounts of $7,848.90            
          and $10,246.60, respectively.  They claimed Schedule C deductions           
          for self-employment tax on the returns in the amounts of                    
          $7,848.90 and $10,246.60, respectively.                                     
               Through adjustments made to petitioners' 1990 and 1991                 
          returns at the Memphis Service Center, petitioners were allowed             
          to deduct one-half of the self-employment tax reported by them on           
          their 1990 and 1991 returns.                                                


          2  Petitioners erroneously calculated the $15,128 interest                  
          income reported on their Federal income tax return for the                  
          taxable year 1990.  The individual items of interest income                 
          detailed by petitioners on Schedule B attached to their 1990                
          return total $15,068, which is $60 less than $15,128.  Thus, in             
          the notice of deficiency respondent determined that petitioners             
          failed to report interest income in the amount of $2,824, which             
          is $60 less than the amount of interest income petitioners failed           
          to disclose on Schedule B attached to their 1990 return.                    



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