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income as income from “Personal use of company vehicle”.
In petitioners’ 1997 joint return, petitioners claimed,
inter alia, deductions for the respective $2,000 contributions
made to Mr. Whitehead’s IRA and to Ms. Whitehead’s IRA.
Notice of Deficiency
In the notice issued to petitioners for the years at issue,
respondent determined, inter alia, to increase petitioners’
taxable income for each year at issue by $24,000. Respondent
made those determinations because respondent determined that Mr.
Whitehead received from Burien Nissan constructive dividends of
$24,000 during each such year.
Respondent further determined to increase petitioners’
taxable income for each year at issue in an amount equal to the
aggregate value of petitioners’ respective uses of certain Burien
Nissan automobiles.18 Respondent made those determinations
18Respondent determined that the aggregate value of peti-
tioners’ respective uses of certain Burien Nissan automobiles
during each year at issue was $15,000. With respect to petition-
ers’ tax year 1996, respondent credited petitioners for the
following items of income reported in their 1996 joint return:
(1) $1,800 of wage income identified as “EPV” in Mr. Whitehead’s
1996 Form W-2, (2) $750 of other income from Burien Nissan, and
(3) $6,600 of alleged self-employment income from Burien Nissan,
which respondent determined was not self-employment income.
Respondent’s crediting of the foregoing items of income reported
in petitioners’ 1996 joint return resulted in a determination in
the notice to increase petitioners’ taxable income for 1996 in
the net amount of $5,850. With respect to petitioners’ tax year
1997, respondent credited petitioners for the following items of
income reported in their 1997 joint return: (1) $1,800 of wage
income identified as “EPV” in Mr. Whitehead’s 1997 Form W-2 and
(continued...)
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