Jane B. Oliver and Robert P. Oliver - Page 48

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          one-half of the self-employment tax for the taxable year is                 
          allowed as a deduction.                                                     
               Through adjustments made to petitioners' 1990 and 1991                 
          income tax returns at the Memphis Service Center, petitioners               
          were allowed to deduct one-half of the self-employment tax                  
          reported by them on those returns.                                          
               Petitioners contend that they are entitled to a deduction              
          for the full amount of self-employment tax paid by them in 1990             
          and 1991 in the amounts of $7,849 and $10,246, respectively.                
          However, petitioners offer no support for this contention.                  
          Respondent counters with the assertion that the deductions                  
          claimed by petitioners on their returns for 1990 and 1991 for the           
          full amount of self-employment tax paid by them should be                   
          disallowed.  Because petitioners were previously allowed a                  
          deduction for one-half of the self-employment tax reported by               
          them on their returns for 1990 and 1991, as provided in section             
          164(f), we agree with respondent that the full amount of the                
          deductions claimed by them on their returns for 1990 and 1991               
          should be disallowed.  We so hold.                                          
          V.  Issue 10.  Statute of Limitations on Assessment for 1990                
               Petitioners contend that respondent's notice of deficiency             
          for 1990 was issued after the statutory period for the assessment           
          of a tax deficiency had expired.  This issue was raised for the             
          first time in petitioners' brief.                                           






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