Joe T. Kieffer and Linda R. Kieffer - Page 2

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          $1,509, respectively and accuracy-related penalties in the                  
          amounts of $375 and $302, respectively.                                     
               The issues for decision are whether petitioners' income from           
          the sale of lumber by petitioner Joe T. Kieffer (petitioner) is             
          exempt from income tax and whether petitioners are liable for the           
          accuracy-related penalty under section 6662.  If we find that the           
          income from lumber sales is subject to income tax, the parties              
          agree that petitioners are entitled to trade and business expense           
          deductions in the amounts of $11,214 in 1993 and $6,954 in 1994,            
          and self-employment tax deductions in the amounts of $427 in 1993           
          and $265 in 1994.                                                           
               All of the facts are stipulated and are so found.  The                 
          stipulation of facts and the attached exhibits are incorporated             
          herein by reference.  Petitioners resided in Fruitland,                     
          Washington, at the time their petition was filed.                           
                                   Background                                         
               In 1993 and 1994 petitioners were and currently are enrolled           
          members of the Spokane Indian Tribe (tribe).  Petitioner was                
          self-employed in 1993 and 1994.  He harvested diseased timber on            
          the tribal reservation pursuant to a tribal permit allowing him             
          to conduct such activity.  Reservation land was and continues to            
          be land not allotted to individual Indians.                                 
               Petitioner transported the timber he harvested on                      
          reservation land to "his property" where it was cut into lumber.            





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