- 9 -
SCHOOL DIST. # 611”, and $13,122.3816 of wages from JJ & P Farms,
Inc. In Schedule E, Supplemental Income and Loss (Schedule E),
included as part of petitioners’ 1993 return, petitioners re-
ported $52,050 in rent received from the rental of petitioners’
farmland and petitioners’ personal property (1993 claimed rent),
$27,212 in expenses, and $24,838 in total rental real estate
income.
In petitioners’ 1994 return, petitioners reported that Mr.
Solvie and Ms. Solvie received $16,356.29 and $5,808.86,17 re-
16The parties stipulated that petitioners reported in peti-
tioners’ 1993 return that Ms. Solvie received $13,122.21 of wages
from JJ & P, Farms, Inc. That stipulation is clearly contrary to
petitioners’ 1993 return. That return shows that petitioners
reported that for 1993 they received a total of $31,650 of
“Wages, salaries, tips, etc.”, $18,423.62 of which Mr. Solvie
reported as wages from JJ & P Farms, Inc., and $104 of which Ms.
Solvie reported as wages from sources other than JJ & P Farms,
Inc. The difference between (1) the total of the wages (i.e.,
$31,650) reported from all sources and (2) the total of the wages
(i.e., $18,527.62) that Mr. Solvie reported from JJ & P Farms,
Inc., (i.e., $18,423.62) and the total of the wages that Ms.
Solvie reported from sources other than that company (i.e., $104)
is $13,122.38. We shall disregard the parties’ stipulation
regarding the amount of wages that petitioners reported in
petitioners’ 1993 return Ms. Solvie received from JJ & P Farms,
Inc. See Cal-Maine Foods, Inc. v. Commissioner, supra.
17The parties stipulated that petitioners reported in peti-
tioners’ 1994 return that Ms. Solvie received $5,808 of wages
from JJ & P, Farms, Inc. Petitioners’ 1994 return shows that
petitioners reported that for 1994 Ms. Solvie received $5,808.86
of wages from JJ & P Farms, Inc. The parties erroneously stipu-
lated down to the nearest dollar instead of up to the nearest
dollar. We shall disregard the parties’ stipulation regarding
the amount of wages that petitioners reported in petitioners’
1994 return Ms. Solvie received from JJ & P Farms, Inc. See Cal-
Maine Foods, Inc. v. Commissioner, supra.
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