Calvin L. Eubanks - Page 5




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          petitioner’s 1992 return based in part upon the information                 
          reported on the Forms 1099 and other information provided by                
          petitioner.                                                                 
               Ultimately, petitioner’s 1992 Federal income tax return was            
          filed on August 12, 1998.  The return includes a Schedule C,                
          Profit or Loss From Business, on which the following items are              
          reported:                                                                   
                         Income                   $34,712                             
                         Expenses:                                                    
                        Car and truck            3,000                               
                        Rent or lease            4,000                               
                        Repairs, etc.            3,000                               
                        Supplies                 1,000                               
                         Net profit               23,712                              
          The income reported on the Schedule C represents the sum of the             
          amounts reported on the Forms 1099.  No other income is reported            
          on petitioner’s 1992 return.  The net profit reported on the                
          Schedule C is treated as net earnings from self-employment.  The            
          Federal income tax liability of $5,769 reported on the return               
          consists of a section 1 income tax liability of $2,419 and a                
          $3,350 section 1401 tax on self-employment income.  The section 1           
          income tax liability takes into account petitioner’s filing                 
          status as single, a personal exemption deduction, the appropriate           
          standard deduction, and a deduction for one-half of the section             
          1401 tax.                                                                   








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