Kevin D. Castro and Margarita C. Castro, et al. - Page 13




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          the CFT, as “other income” subject to self-employment tax on the            
          Castros’ jointly filed Form 1040 for 1995.  In respondent’s                 
          notice of deficiency to the Castros, respondent increased the               
          Castros’ income by the jewelry business’ net profit and decreased           
          the Castros’ income by the fiduciary fees received.                         
               B.  1996                                                               
               The CCJT filed a timely Form 1041 for 1996.  The CCJT                  
          reported income and expenses allocable to the jewelry business on           
          Schedule C of its return and also claimed deductions for                    
          fiduciary fees and a distribution to the CFT of all but $197 of             
          its net income.  The CCJT paid income tax of $15 for 1996.  In              
          respondent’s notice of deficiency to the CCJT, respondent                   
          disallowed all of the deductions and increased the jewelry                  
          business’ net profit accordingly.                                           
               The CFT filed a timely Form 1041 for 1996.  The CFT reported           
          the income it received from the CCJT on Schedule E to its return.           
          The CFT also claimed deductions for fiduciary fees, charitable              
          contributions, and medical, utilities, automobile, meal, travel,            
          and telephone expenses.  The CFT paid income tax of $16 for 1996.           
          In respondent’s notice of deficiency to the CFT, respondent                 
          disallowed all of the CFT’s deductions.                                     
               Petitioner reported the fiduciary fees he received from the            
          CCJT, and Mrs. Castro reported the fiduciary fees she received              
          from the CFT, as “other income” subject to self-employment tax on           






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