- 2 - and characterizations of gross income determined in the notices of deficiency are correct; and (2) whether petitioners incurred a loss in 1987 which they may use to offset their gross income for 1995, 1996, and 1997. Background Respondent determined deficiencies in petitioners’ Federal income taxes and additions to tax as follows: Mr. Tonn Additions to tax Year Deficiency Sec. 6651(a)(1) Sec. 6654 1995 $592 $148.00 $32.10 1996 1,165 291.25 62.02 1997 1,279 319.75 68.45 Mrs. Tonn Additions to tax Year Deficiency Sec. 6651(a)(1) Sec. 6654 1996 $18,801 $4,700.25 $1,000.68 1997 15,539 3,884.75 831.34 In the notices of deficiency, respondent determined the following amounts and characterizations of petitioners’ gross income: Mr. Tonn Year Interest Income Self-Employment Income Rental Income 1995 $153 $4,187 -- 1996 246 7,169 -- 1997 360 2,820 $9,000 Mrs. Tonn Year Self-Employment Income 1996 $57,429 1997 49,614Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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