Bruce A. and Kathy J. Krist - Page 13




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               As previously stated, petitioners had borrowed $10,200 that            
          was deposited in an account held for them by petitioner’s mother.           
          That amount is not income to petitioners.  On this record we find           
          there were no other nonincome items to reduce the remaining                 
          $9,440.  Consequently, we find that petitioners had unreported              
          additional income of $9,440 under the bank deposits method.                 
               We agree with respondent that this additional $9,440 is                
          subject to self-employment tax under section 1401, and                      
          petitioners are entitled to a corresponding 50-percent deduction            
          under section 164(f).                                                       
          5.   Claimed Casualty Loss                                                  
               Respondent contends that petitioners are not entitled to a             
          casualty loss of $15,800 for the seizure and destruction of the             
          guns held for their alleged firearms business.  Petitioners                 
          claimed this loss on their amended return filed on April 16,                
          1999.  No evidence was presented regarding this issue.                      
          Accordingly, we deem petitioners to have abandoned it.  Calcutt             
          v. Commissioner, 84 T.C. 716, 721-722 (1985); German v.                     
          Commissioner, T.C. Memo. 1993-59, affd. without published opinion           
          46 F.3d 1141 (9th Cir. 1995).  We hold that petitioners are not             
          entitled to a casualty loss.                                                
          6.   Addition to Tax for Failure To File Timely Returns                     
               Section 6651(a)(1) imposes an addition to tax for failure to           
          file a Federal income tax return by its due date, determined with           
          regard to any extension of time for filing previously granted.              






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