Orneal and Martha Kooyers, et al. - Page 3

                                        - 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, petitioners               






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011