Herbert L. Whitehead and Jennifer L. Whitehead - Page 34




                                       - 34 -                                         
          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.                                                        





Page:  Previous  24  25  26  27  28  29  30  31  32  33  34  35  36  37  38  39  40  41  42  43  Next

Last modified: May 25, 2011