- 3 -
Additional adjustments to petitioners’ exemptions, itemized
deductions, self-employment tax, and deduction for self-
employment tax are computational in nature and will be resolved
by our holdings on the foregoing issues.
Unless otherwise indicated, all section references are to
sections of the Internal Revenue Code in effect for the year at
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
To facilitate disposition of the above issues, we shall
first make general findings of fact and then combine our findings
and opinion with respect to each issue.
I. General Findings of Fact
Some of the facts have been stipulated and are so found.
The stipulations of the parties, with accompanying exhibits, are
incorporated herein by this reference. At the time the petition
was filed in this case, petitioners resided in Newport Beach,
California.
Petitioners requested two extensions of time to file their
1993 Form 1040, U.S. Individual Income Tax Return, both of which
were granted. Taking these extensions into account, petitioners’
return was due on October 15, 1994. Respondent received
petitioners’ 1993 Form 1040 on December 15, 1995. The return was
signed by both petitioners and by their preparer Anthony Aulisio,
Jr., CPA. Attached to their 1993 return, petitioners included
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011