- 2 - Curtis Bennett and Marie Bennett Year Deficiency 1995 $4,194 1996 3,492 Gerhard W. Schmitz and Betty J. Schmitz Year Deficiency 1995 $4,226 1996 4,734 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The issue for decision is whether partnership activity constituted a trade or business, triggering self-employment tax liability on partnership income for the partners of the partnership. Background The facts of these cases were submitted fully stipulated under Rule 122, and are so found. At the time the petitions were filed, petitioners Curtis and Marie Bennett resided in Gering, Nebraska, and petitioners Gerhard W. and Betty J. Schmitz resided in Scottsbluff, Nebraska (hereinafter references to petitioners are generally to Curtis Bennett and Gerhard Schmitz). On January 1, 1991, petitioners, as equal partners, organized Lucky Keno (Lucky) as a general partnership toPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011