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After concessions by the parties, we decide the following
issues for 1992:1
1. Whether petitioners must include in income $27,998 from
the sale of real property. We hold they must to the extent set
forth herein.
2. Whether petitioners are entitled to Schedule A itemized
deductions of $11,305. We hold they are to the extent set forth
herein.
3. Whether petitioners are entitled to Schedule C expenses
of $21,578. We hold they are not.
4. Whether petitioners are liable for self-employment tax
of $4,246. We hold they are.
5. Whether petitioners are liable for the addition to tax
under section 6651 determined by respondent. We hold they are.
6. Whether petitioners are liable for the penalty under
section 6662 determined by respondent. We hold they are.
Unless otherwise noted, section references are to the
Internal Revenue Code in effect for 1992. Rule references are to
the Tax Court Rules of Practice and Procedure. References to
petitioner are to Ron L. Stevenson.
1Respondent briefed the issue of whether petitioners were
entitled to a dependency exemption for their daughter, Jill
Stevenson. Petitioners specifically conceded this issue at
trial, and we do not address it herein.
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