Robert E. Wadlow and Connie V. Wadlow - Page 3




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          executed Forms 5213 to their returns for 1990, 1991, 1992, and              
          1993, all of which were timely filed.                                       
               Respondent mailed notices of deficiency to petitioners on              
          August 15, 1996, which were timely under section 183(e)(4), see             
          infra, determining deficiencies in income tax of $6,828, $5,763,            
          $7,182, $5,924, and $10,481 for 1990, 1991, 1992, 1993, and 1994,           
          respectively.  The deficiency notices addressed only deficiencies           
          arising from deductions for activity-related expenses claimed on            
          Schedules C.  Only petitioners' 1991 and 1992 taxable years                 
          remain in dispute.                                                          
               For their 1991 taxable year, petitioners made tax payments             
          of $7,568.37, all of which were credited to their IRS account on            
          April 15, 1992.  On May 25, 1992, respondent allowed and paid in            
          full the $277.37 refund claimed by petitioners on their 1991 tax            
          return, resulting in a $7,291 net payment of tax.                           
               For their 1992 taxable year, petitioners made tax payments             
          of $9,255, all of which were credited to their IRS account on or            
          before April 15, 1993.                                                      
               The deficiency notice for 1991 reflects (1) the disallowance           
          of all Schedule C expenses, totaling $14,702; (2) a correlative             
          adjusted gross income adjustment in the amount of $957; and (3) a           
          related self-employment tax of $1,914.                                      
               The deficiency notice for 1992 reflects (1) the disallowance           
          of all Schedule C expenses, totaling $18,855; (2) a correlative             





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