- 2 - Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. After concessions, the issues for decision are: (1) Whether amounts paid for certain truck dispatch services performed by petitioners are attributable to petitioners' wholly owned S corporation or to petitioner Julie Ruckman and thus subject to self-employment tax; (2) whether petitioners are entitled to depreciation deductions in the amount of $12,285 for each of the years 1990 and 1991; and (3) whether petitioners are liable for an accuracy-related penalty under section 6662(b)(1) for failing to report certain income in 1991.1 FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. Petitioners Robert G. Ruckman (Mr. Ruckman) and Julie Ruckman (Mrs. Ruckman) are husband and wife who resided in Leivasy, West Virginia, at the time their petition was filed. 1Respondent made determinations with respect to petitioners' wholly owned S corporation, Robert Ruckman, Inc., at the shareholder level, as provided for in sec. 301.6241-1T(c)(2), Temporary Proced. & Admin. Regs., 52 Fed. Reg. 3002 (Jan. 30, 1987). The parties have not disputed this aspect of the determination.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011