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