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as a result of Burien Nissan’s payments to Mr. Stanford during
each such year. On the instant record, we sustain those determi-
nations.
Petitioners’ Respective Uses of Certain Burien Nissan Automobiles
Respondent determined to increase petitioners’ taxable
income for 1996 and 1997 in the net amounts of $5,850 and $6,600,
respectively, as a result of petitioners’ respective uses during
those years of certain Burien Nissan automobiles. Respondent
made those determinations because respondent determined that
petitioners did not provide adequate records or other documenta-
tion to substantiate any business use of those automobiles during
each year at issue. Respondent further determined that petition-
ers’ respective uses of certain Burien Nissan automobiles during
the years at issue resulted in employee income attributable to
Mr. Whitehead for those years and did not result in self-employ-
ment income attributable to Ms. Whitehead for 1996 or to Mr.
Whitehead for 1997.29 Petitioners advance a number of conten-
tions with respect to respondent’s determinations regarding their
29The parties agree that petitioners reported the value of
their respective uses of certain Burien Nissan automobiles in
petitioners’ 1996 joint return as follows: Wage income of $1,800
attributable to Mr. Whitehead, “Other income” of $750, and “Other
income” of $6,600 attributable to Ms. Whitehead and subject to
self-employment tax. The parties further agree that petitioners
reported the value of their respective uses of certain Burien
Nissan automobiles in petitioners’ 1997 joint return as follows:
Wage income attributable to Mr. Whitehead of $1,800 and “Other
income” of $6,600 attributable to Mr. Whitehead and subject to
self-employment tax.
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