Herbert L. Whitehead and Jennifer L. Whitehead - Page 25




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          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.                                





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