Robert G. Ruckman and Julie Ruckman - Page 2

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               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.                                                              





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