- 41 -
or losses. Both partnerships were engaged in the business of
selling real estate.
On their 1990 and 1991 Forms 1065, the partnerships reported
the following:
1990 1991
100-Lot Kiddies 38/91 100-Lot Kiddies 38/91
Interest
income $15,717 $21,582.58 $13,191 $23,195
Ordinary
income 11,372 48,071.84 (17,339) 91,092
Guaranteed
payments to
petitioner
as partner 20,800 15,000.00 19,200 15,100
Petitioner provided management services to Eureka Field
Nursery during 1991. Petitioner was paid $6,421 in management
fees for the services that he provided Eureka Field Nursery
during 1991.
Petitioner managed and acted as a consultant for a number of
his S corporations and partnerships, negotiating most, if not
all, of their land sales.
On the Kiddies 38/91 Form 1065 for 1993, the partnership
reported $52,748 of ordinary income and that it made $8,900 of
guaranteed payments to partners.
B. Discussion
Petitioner argues that he is not subject to the self-
employment tax on moneys that he received from the 100-lot and
Kiddies 38/91 partnerships in 1990, 1991, and 1993.
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