Joe D. and Maura F. White - Page 4




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               Petitioners did not include with their return a Schedule C,            
          Profit or Loss From Business, with respect to the $4,995.03 in              
          self-employment income, nor did they claim deductions for                   
          expenses in connection with the activity or compute self-                   
          employment taxes on the income.  The three sources of this income           
          reflected on the Forms 1099-MISC earned by petitioner were from             
          the following sources:                                                      

               Xprezzo Caffe Club, 11c                 $1,328.03                      
               Villa Del Rio                            1,662.00                      
               Rio Grande Property Management           2,005.00                      
          Total                                 $4,995.03                             

               In the notice of deficiency, respondent determined a                   
          deficiency of $654 in taxes, representing self-employment taxes             
          due under section 1401(a) and allowing petitioners a deduction              
          for one-half of the taxes under section 164(f).  Respondent's               
          determination, however, was based only on two of the Forms 1099-            
          MISC identified above, $1,662 from Villa Del Rio, and $2,005 from           
          Rio Grande Property Management, totaling $3,667.  Respondent's              
          determination failed to include the $1,328.03 shown above in the            
          deficiency determination.                                                   
               In preparation for trial, petitioners prepared and submitted           
          to respondent an income tax return, Form 1040, for 1999, on which           
          they correctly reported their income from the various sources               








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