- 3 - determined by respondent. We hold that they are taxable on capital gains of $103,791. Third, we decide whether petitioners may deduct expenses claimed as business expenses by the OMK trusts. We hold that they may not. Fourth, we decide whether petitioners are liable for self- employment taxes on compensation paid to the OMK trusts by Pacific Island Ministries (P.I. Ministries). We hold that they are. Finally, we decide whether petitioners are liable for the accuracy-related penalty under section 6662(a). We hold that they are. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the accompanying exhibits are incorporated in these findings by this reference. When the petitions in these cases were filed, petitioners, who are married, resided in Grass Valley, California, where, at that time, they conducted the activities of the OMK trusts. A. Petitioners’ Missionary Service in New Guinea In the spring of 1959, Mr. Kooyers had an epiphany and believed himself called to serve as a missionary. At the time, petitioners were teaching in northern California. After obtaining releases from their teaching contracts, petitionersPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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