Richard and Judith Haeder - Page 6




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          Gross          Total        Net profit                                      
          Year       Receipts       Expenses       or (loss)                          
               1989         $153         $19,695        ($19,542)                     
               1990           –-          23,462         (23,462)                     
               1991          209          24,144         (23,935)                     
               1992           –-          13,991         (13,991)                     
               1993           –-          23,769         (23,769)                     
          Most of the income reported on petitioners’ returns for 1989                
          through 1993 was investment income.                                         
               Respondent audited petitioners’ returns for the years in               
          issue and made adjustments to income and deductions.  We address            
          the issues remaining for decision below.                                    
          Wages and IRA Deductions                                                    
               In Rapid City, South Dakota, petitioner maintained his law             
          office in his residence.  He had no office help outside of                  
          whatever assistance Mrs. Haeder gave him.  Mrs. Haeder usually              
          answered the telephone, greeted visitors, and cleaned the house,            
          including petitioner’s office.  At his residence, petitioner                
          initially had only one telephone line for both business and                 
          personal use.  Eventually he had a second line installed to                 
          accommodate a fax machine.                                                  
               On a date that does not appear in the record, petitioner               
          decided to start paying Mrs. Haeder a salary.  Petitioner did not           
          determine Mrs. Haeder’s salary on the basis of hours worked or              
          services performed; instead, he based her salary on the maximum             
          amount a qualified individual could deduct for qualifying                   





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