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share of taxable community property income for the 1995 taxable
year and the correct amount of such income; (3) whether each
petitioner is liable for self-employment tax for the 1995 tax
year; and (4) whether each petitioner is liable for the addition
to tax under section 6651(a)(1) for failure to timely file a
Federal income tax return for the 1995 tax year.
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. At the time the petition
was filed, petitioners resided in San Antonio, Texas.
FINDINGS OF FACT
In 1994, petitioner worked for Alamo Body and Paint (Alamo)
in San Antonio. In late 1994, petitioner quit his job at Alamo
and decided to open a restaurant called Villa Cabana.
Petitioners signed a 3-year lease for commercial space in
San Antonio, bought equipment, and stocked the restaurant with
food and supplies. Petitioners also attended courses in food
handling and arranged for business and health department
licensing. After some initial difficulty with a natural gas
leak, Villa Cabana opened for business on December 23, 1994.
Beginning in 1995, petitioners hired additional people to
work in the restaurant, but the record is not clear as to the
type of work performed by the additional help. Petitioner worked
as the restaurant cook and petitioner wife waited tables.
Petitioner also purchased supplies for the restaurant.
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