- 46 -
With respect to the parties’ dispute as to whether Ms.
Whitehead performed services for Burien Nissan during the years
at issue, petitioners contend that those services included
“performing administrative tasks, functioning as corporate
Secretary, assisting with the transporting of vehicles when sales
promotions were conducted away from the dealership site and
coordinating employee functions at two or more major events
during the operating year.”38 In support of petitioners’ conten-
tion that Ms. Whitehead performed those services for Burien
Nissan during the years at issue, petitioners rely on their self-
serving testimony. We are not required to, and we shall not,
rely on Mr. Whitehead’s testimony. Based on the Court’s evalua-
tion of Ms. Whitehead’s testimony, we are not required to, and we
shall not, rely on her testimony to establish that she performed
37(...continued)
Burien Nissan automobiles, and that use had a value of $6,600.
Nevertheless, petitioners contend that that $6,600 constitutes
self-employment income attributable to Ms. Whitehead for 1996 and
to Mr. Whitehead for 1997. It is not altogether clear why
petitioners are claiming inconsistent treatment of the value of
Ms. Whitehead’s alleged services and use of certain Burien Nissan
automobiles for each year at issue. However, as discussed below,
we believe that the reason for such inconsistent treatment is
that, in order to be entitled to a deduction for the entire
$2,000 contribution to her IRA for 1996, Ms. Whitehead would have
to have received compensation for that year of at least $2,000.
In contrast, due to a change in the law, she would not have to
have received any compensation in order to be entitled to a
deduction for the entire $2,000 contribution to her IRA for 1997.
38Petitioners concede that Ms. Whitehead did not have any
written agreement with respect to any services that petitioners
claim she performed for Burien Nissan during the years at issue.
Page: Previous 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 NextLast modified: May 25, 2011