Frank and Lou-Ann Guarna - Page 12

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               Based on our findings above, petitioner is entitled to                 
          Schedule C expense deductions relating to the L.A. Models Inc.              
          job, as follows:                                                            
                    Pictures            $78.00                                        
                    Parking             20.00                                         
                    Agent               450.00                                        
                    Directories         6.00                                          
                    Education           27.00                                         
                    Dues                3.00                                          
                    Phone               14.00                                         
                    Supplies            4.00                                          
                    Ent., publicity &                                                 
                    networking          130.00                                        
                    Mileage              176.00                                       
                    Total expenses       $908.00                                      
               Accordingly, respondent must subtract $908.00 of                       
          unreimbursed business expense from petitioners’ 1997 Schedule A             
          to account for the expense deductions now allowed on Schedule C.            
               Petitioner’s net income from self-employment relating to the           
          L.A. Models Inc. job is as follows:                                         
                    Self-employment income    $2,250.00                               
                    Total expenses               908.00                               
                    Net income                $1,342.00                               
          Self-Employment Tax                                                         
              Respondent determined that petitioners are liable for $318             
          of self-employment tax on the $2,250 of income received from L.A.           
          Models Inc.  Section 1401 imposes a tax on the self-employment              
          income of individuals.                                                      
               Self-employment income means the net earnings from self-               
          employment derived by an individual.  Sec. 1402(b).  In general,            






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