Herbert L. Whitehead and Jennifer L. Whitehead - Page 23




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          inter alia, deductions for the respective $2,000 contributions              
          made to Mr. Whitehead’s IRA and to Ms. Whitehead’s IRA.                     
               In petitioners’ 1997 joint return, petitioners reported,               
          inter alia, wage income attributable to Mr. Whitehead of                    
          $120,53716 and other income described as “Personal use of company           
          vehicle” of $6,600 as shown in Schedule SE that petitioners                 
          included in their 1997 joint return.                                        
               Petitioners’ 1997 joint return included Schedule A.  In that           
          schedule, petitioners claimed, inter alia, the following deduc-             
          tions:  (1) $7,422 for real estate taxes, (2) $35,504 for mort-             
          gage interest, and (3) $79 for points not reported in Form                  
          1098.17                                                                     
               Petitioners’ 1997 joint return also included Schedule SE.              
          In that schedule, petitioners reported self-employment income               
          attributable to Mr. Whitehead of $6,600.  Petitioners’ 1997 joint           
          return included a statement in which petitioners described that             


               16Petitioners attached to petitioners’ 1997 joint return               
          Form W-2 for 1997 for Mr. Whitehead (Mr. Whitehead’s 1997 Form W-           
          2).  That form showed “BURIEN NISSAN ADMINISTRATION” as employer            
          and Mr. Whitehead as employee.  Mr. Whitehead’s 1997 Form W-2               
          showed, inter alia, “Wages, tips, other compensation” in the                
          amount of $120,537.03.  That form indicated that that amount                
          included a benefit of $1,800 that was identified in that form as            
          “EPV”.  As discussed supra note 12, we believe “EPV” stands for             
          “employer provided vehicle”.                                                
               17The $79 deduction claimed for points not reported in Form            
          1098 represented petitioners’ amortization of points that they              
          claim they paid with respect to the refinancing of the Kirkland             
          property in February 1994.                                                  





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