48- -
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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