- 2 -
deficiencies in petitioner's 1993 and 1994 Federal income taxes
in the amounts of $1,090 and $1,339, respectively.
After a concession by respondent, the issues are: (1)
Whether petitioner is liable for self-employment taxes; and (2)
whether petitioner is entitled to a dependency exemption
deduction.
Some of the facts have been stipulated and are so found.
The stipulation of facts and attached exhibits are incorporated
herein by this reference. Petitioner resided in Oakland,
California, at the time the petition was filed.
On his 1993 and 1994 Federal income tax returns, petitioner
reported income from "Wages, salaries, tips, etc." in the amounts
of $4,500 and $8,200, respectively. No Forms W-2 were attached
to his return for either year in issue. Petitioner listed his
occupation as "unemployed part-time salesman" on both returns.
Respondent determined that the $4,500 and $8,200 income
petitioner reported on his 1993 and 1994 returns, respectively,
constituted earnings from self-employment, and therefore
petitioner was liable for self-employment taxes. Further,
respondent allowed petitioner a deduction for one-half of the
self-employment taxes, and made computational adjustments to
petitioner's earned income credits. In his amended petition,
petitioner sought to claim a dependency exemption deduction for
his "eldest son", for both years in issue.
Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011