- 43 - Petitioner also argues that the only services that he provided were for Farm & Grove. This argument ignores the fact that during the years in issue, petitioner was a general partner at both the 100-lot and the Kiddies 38/91 partnerships. During the years in issue, the partnerships conducted businesses and reported distributing profits and losses as well as guaranteed payments to petitioner. Thus, petitioner is liable for the self- employment tax. We hold that petitioner is liable for the self-employment tax based on moneys that he received from the 100-lot and Kiddies 38/91 partnerships in 1990, 1991, and 1993.46 VII. Issue 7. Flow-Through Adjustment A. Background On Schedule K-1 of its 1990 and 1991 Form 1065, the 100-lot partnership reported petitioner’s share of income as $11,372 in 1990 and a loss of $17,339 in 1991. Petitioner reported the $11,372 in income from the 100-lot partnership on his amended 1990 Federal income tax return, and he reported the $17,339 loss on his 1991 Federal income tax return. B. Discussion Petitioner argues that the reported income and loss from the 100-lot partnership should be stricken from his 1990 and 1991 46Petitioner is entitled to a deduction in 1990, 1991, and 1993 for paying the self-employment tax. See sec. 164(f).Page: Previous 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 Next
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