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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 to
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