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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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