-2-
taxes, respectively. Following petitioners’ concession,1 we must
decide:
1. Whether petitioners are liable for self-employment taxes
of $4,923, $4,551, and $5,008 in 1995, 1996, and 1997,
respectively, as determined by respondent. We hold they are.2
2. Whether petitioners may deduct charitable contributions
of $13,900, $20,575, and $23,467 on their respective 1995, 1996,
and 1997 Schedules C, Profit or Loss From Business. We hold they
may not.
3. Whether we should penalize petitioners under section
6673.3 We hold we should and penalize them $1,000.
FINDINGS OF FACT
Most facts were stipulated. We incorporate herein by this
reference the parties’ stipulation of facts and the accompanying
exhibits. Petitioners resided in Spokane, Washington, when their
petition was filed with the Court.
1 Respondent determined that petitioners received and failed
to report $115 in interest income in 1997. Petitioners’ petition
and brief are silent as to this determination. We sustain this
determination without further comment. See Jarvis v.
Commissioner, 78 T.C. 646, 658 n.19 (1982).
2 By virtue of this holding, we also sustain respondent’s
determination that petitioners may deduct one-half of each year’s
self-employment tax under sec. 164(f).
3 Section references are to the Internal Revenue Code in
effect for the subject years. Rule references are to the Tax
Court Rules of Practice and Procedure.
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