Raymond F. Kling and Barbara K. Kling - Page 49




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               1992                                                                   
                    Gross receipts                                                    
                         Notice of Deficiency     $91,972                             
                         Star Bank miscellaneous     (886)                            
                         Total                    91,086                              
                    Purchases                                                         
                         Notice of Deficiency     58,971                              
                         Additional               10,313                              
                         Dishonored checks         (18,130)                           
                         Total                    51,154                              
                    Omitted Income                                                    
                         Gross receipts           91,086                              
                         Purchases                (51,154)                            
                         Rent                       (5,000)                           
                         Total                    34,932                              
          Issue 2.  Whether Petitioners Are Liable for Self-Employment Tax            
          on the Net Income From the Sports Memorabilia Activity                      
               Section 1401 imposes a tax on a taxpayer's self-employment             
          income.  Self-employment income includes the net earnings from              
          self-employment derived by an individual during the taxable year.           
          See sec. 1402(b).  Net earnings from self-employment means the              
          gross income derived by an individual from any trade or business            
          carried on by the individual, less allowable deductions                     
          attributable to the trade or business, plus certain items not               
          relevant here.  See sec. 1402(a).  With certain exceptions not              
          here applicable, the term "trade or business" for purposes of the           
          self-employment tax generally has the same meaning as used for              
          purposes of section 162.  Sec. 1402(c).  Thus, to be engaged in a           
          trade or business within the meaning of section 1402(a), an                 
          individual must be involved in an activity with continuity and              
          regularity, and the primary purpose for engaging in the activity            
          must be for income and profit.  See Commissioner v. Groetzinger,            






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