Matthew W. Norwood and Linda D. Kramer - Page 2

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               After a concession by petitioners, the only issue which                
          this Court must decide is whether petitioners are liable for                
          self-employment tax under section 1401 on a distribution received           
          from a partnership.                                                         
               Some of the facts in this case have been stipulated and are            
          so found.  Petitioners resided in Coronado, California, at the              
          time they filed their petition.                                             
               In 1995, petitioners both worked in sales.  Matthew Norwood            
          (petitioner) sold yachts.  Linda Kramer was employed by Lasorda             
          Staff Leasing, LLC and by Designed Administrative Resources Tech.           
          During 1995, petitioner was also a general partner of Gallant               
          Medical Supply (Gallant), a partnership.  Petitioner's percentage           
          of profit and loss sharing for Gallant was 50.95 percent.                   
          Additionally, petitioner owned 50.95 percent of the capital of              
          Gallant.                                                                    
               Petitioner started Gallant a number of years ago.  He had              
          worked at Gallant full time, but when the staff could operate the           
          business without him, petitioner stopped working there.  During             
          1995, petitioner spent approximately 41 hours on partnership                
          matters.  He conducted periodic walkthroughs of Gallant and was             
          consulted on major decisions of the firm.  In 1995, petitioner              
          received $71,194 as his distributive share of Gallant's income.             
          Petitioners correctly included the $71,194 distribution as                  
          taxable income on Schedule E, Supplemental Income and Loss, of              





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