- 25 -
because respondent determined that petitioners did not provide
adequate records or other documentation to substantiate any
business use of certain Burien Nissan automobiles during each
such year. In this connection, respondent also determined that
petitioners did not have any self-employment income during each
of the years at issue. Respondent made those determinations
because respondent determined that the aggregate value of peti-
tioners’ respective uses of certain Burien Nissan automobiles
during each of those years must be reported as employee income
attributable to Mr. Whitehead and that no part of that value may
be reported, as petitioners had claimed in their joint return for
each of the years at issue, as self-employment income attribut-
able to Ms. Whitehead for 1996 and to Mr. Whitehead for 1997.
Respondent also determined to disallow the deductions
claimed by petitioners for each of the years at issue for mort-
gage interest and property taxes in excess of the amounts de-
ducted by them with respect to the Sumner property. Respondent
further determined to disallow the deduction claimed by petition-
ers for each of the years at issue for points not reported in
Form 1098.
18(...continued)
(2) $6,600 of alleged self-employment income from “Personal use
of company vehicle”, which respondent determined was not self-
employment income. Respondent’s crediting of the foregoing items
of income reported in petitioners’ 1997 joint return resulted in
a determination in the notice to increase petitioners’ taxable
income for 1997 in the net amount of $6,600.
Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 NextLast modified: May 25, 2011