-4- and 1402(a)(5)(A). See Charlton v. Commissioner, 114 T.C. 333, 337 (2000). We denied rental cabin deductions because they were preoperational expenses. See id. at 338. We held that Charlton qualifies for limitation of liability under section 6015(c) to the extent that the unreported Medi-Task income is allocable to Hawthorne. See id. at 340-342. Charlton improperly netted the Medi-Task income and expenses petitioners had reported with expenses of the rental cabins to compute self-employment income. That error caused a self-employment tax deficiency. An additional self-employment tax deficiency occurred because Charlton and Hawthorne underreported Medi-Task income. We accepted respondent’s unopposed suggestion that the parties allocate items under section 6015(d) as part of the Rule 155 computations. See id. at 342. After we filed our opinion in Charlton v. Commissioner, supra, respondent determined that Hawthorne is entitled to relief under section 6015(f). Discussion Respondent contends that the tax on Medi-Task income and the increase in self-employment tax attributable to the unreported Medi-Task income are allocable to Hawthorne, and that the deficiency to the extent that it was attributable to denied rental cabin deductions is allocable to Charlton. Charlton contends that deductions for $2,050 of unclaimed Medi-TaskPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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