- 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
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