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.Page: Previous 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 Next
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