David A. Demetree - Page 12

                                       - 12 -                                         
          David rendered on behalf of NLP and Scooper’s.  See sec. 61(a);             
          James v. United States, supra.  Accordingly, respondent’s                   
          determinations are sustained.                                               
               E.  Interest Income                                                    
               Respondent determined that petitioners failed to report                
          interest income relating to 1986, 1987, 1988, 1989, 1991, and               
          1992.  We sustain respondent’s determinations relating to David’s           
          accounts (i.e., interest earned in 1986, 1987, 1988, 1989, 1991,            
          and 1992), and Deborah’s accounts (i.e., interest earned in                 
          1992).                                                                      
          III.  Petitioners’ Claimed Loss Deductions                                  
               There is no evidence to support petitioners’ claimed 1987,             
          1988, 1989, and 1992 net operating loss deductions or 1992 rental           
          loss deduction.  See sec. 6001; sec. 1.6001-1(a), Income Tax                
          Regs.  Accordingly, respondent’s determinations are sustained.              
          IV. Self-Employment Income                                                  
               Respondent determined that petitioners were liable, pursuant           
          to section 1401, for tax on self-employment income relating to              
          all the years in issue.  We hold that, consistent with our                  
          findings, petitioners are liable for self-employment tax relating           
          to income from NLP, Scooper’s, and David’s property management              
          activities relating to 1991 and 1992.  See sec. 1402(a) and (b).            
          V.   Additions to Tax and Penalties                                         
               Respondent determined additions to tax pursuant to sections            
          6651(a)(1), 6654(a), and 6661.  Section 6651(a)(1) provides an              




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  Next

Last modified: May 25, 2011