- 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 Next
Last modified: May 25, 2011