- 24 - 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...)Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
Last modified: May 25, 2011