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Whether the exemptions claimed for 1995 by the J. Shirleys
must be reduced on account of any increase in their adjusted
gross income.4
Whether the J. Shirleys are liable for penalties under
sections 6662(a) and 6673(a)(1).
Whether the C. Shirleys understated their gross income for
1995 by omitting $25 of interest income, $33,980 of unreported
deposits, and $2,470 of business income.
Whether the C. Shirleys further understated their gross
income for 1995 by omitting (1) $65,951 of gross receipts
attributed to them from C E Shirley Trust and (2) $12,000 of rent
reported by Congo Trust.
Whether the C. Shirleys are entitled to a deduction for 1995
for unreimbursed expenses related to Congo Trust.
Whether the C. Shirleys are liable for self-employment tax
for 1995 allocable to Curtis Shirley (and are entitled to a
related deduction) on account of the omitted unreported deposits
of $33,980.5
3(...continued)
items.
4 This also is a computational matter, which the
J. Shirleys have not separately challenged, and we shall not
further discuss it.
5 As with the J. Shirleys, the amount of petitioners’
liability for self-employment tax and the amount of the deduction
under sec. 164(f) to which petitioners are entitled are
(continued...)
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