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years. Respondent determined that all of that compensation is
wage income except (1) $37,338 that Mr. Anderson received during
1992 from Rancho Trucking, Inc. and American Containers Trans.
and (2) $66,448 that he received during 1993 from Zip Truck
Lines, Inc., America Container Trans., and America Pacific
Forwarders, Inc., which respondent determined to be nonemployee
compensation income subject to self-employment tax. We sustain
respondent's determinations regarding petitioner's wage income
for the years 1992 through 1995. However, petitioners denied
that they owe any self-employment tax. Consequently, the self-
employment tax issue for 1992 and 1993 relating to the
compensation that respondent determined to be nonemployee
compensation income remains for adjudication, and respondent
agrees.
While the facts admitted or deemed admitted in this case
establish that during 1992 Mr. Anderson sold real estate for
$275,000, they do not show whether or not he had any basis in
that real estate and/or paid any commissions or other expenses
relating to that sale. Consequently, the issue relating to the
gain, if any, for 1992 from that sale remains for adjudication.
The record in this case also shows that petitioners filed
their return for each of the years 1992, 1993, and 1994 after the
due date for each such return. It does not establish any facts
relating to whether such failure to file timely was due to
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