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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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