William Clovis Williams - Page 2




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               Respondent determined a deficiency in petitioner's Federal             
          income tax for 1994 in the amount of $744.2                                 
               The issue for decision is whether petitioner's earnings from           
          his Schedule C business activity are subject to self-employment             
          tax under section 1401.                                                     
               Some of the facts have been stipulated and are so found.               
          The stipulations of fact and attached exhibits are incorporated             
          herein by this reference.  Petitioner resided in Ragley,                    
          Louisiana, on the date the petition was filed in this case.                 
               Petitioner was a minister during 1994.  He also operated a             
          business which he referred to as Neighborhood Handyman (the                 
          handyman business).  On a Schedule C attached to his 1994                   
          return,3 petitioner reported a net profit from his handyman                 
          business in the amount of $5,263.85.  He did not report any                 
          liability for self-employment taxes with respect to this net                
          profit.  In the statutory notice of deficiency, respondent                  
          determined that petitioner's earnings from his handyman business            
          are subject to self-employment tax.                                         



          2         In paragraph 3 of his Answer, respondent alleges that             
          while the cover page of the notice of deficiency states a                   
          deficiency in the amount of $2,113, the correct deficiency                  
          determined in the notice is $744.                                           
          3         Petitioner and his wife, Wendy A. Williams, filed a               
          joint 1994 Federal income tax return.  The notice of deficiency             
          in this case was issued jointly to petitioner and Mrs. Williams,            
          but Mrs. Williams has not filed a petition in this matter and is            
          not a party to this proceeding.                                             




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