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Laura L. Yoshihara (Mrs. Yoshihara)
Additions to tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1992 $21,958 $5,490 $955
1993 9,551 2,388 399
1994 3,235 809 167
1995 3,492 873 193
Krista A. Yoshihara
Additions to tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1992 $48,493 $12,123 $2,112
1993 19,493 4,873 818
All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
After concessions,1 the issues for decision are: (1)
Whether petitioners had unreported income from landscaping
services for the taxable years 1992, 1993, 1994, and 1995. We
hold they did. (2) Whether Mr. Yoshihara incurred self-
employment tax for the taxable years 1992, 1993, 1994, and 1995.
1On brief, respondent states that the notice of deficiency
relating to 1992 and 1993 sent to Krista A. Yoshihara was only a
protective measure to avoid a whipsaw situation. Accordingly,
respondent concedes that there is no deficiency against Krista A.
Yoshihara for 1992 and 1993 if we sustain the deficiencies
against petitioners Paul I. Yoshihara and Laura L. Yoshihara.
Although the deficiency amounts for 1993 will be recalculated
under a Rule 155 computation to reflect our findings, this
decision does not place respondent in a whipsaw situation.
Therefore, the deficiency determined for Krista A. Yoshihara is
conceded. Consequently, the term "petitioners" in the remainder
of this opinion refers exclusively to Paul I. Yoshihara and Laura
L. Yoshihara.
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