Jere J. and Paulette M. Solvie - Page 11

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          tioners received from JJ & P Farms, Inc., pursuant to the oral              
          rental arrangement and the 1995 claimed rent for petitioners’               
          farmland and petitioners’ personal property that petitioners                
          received from that company pursuant to the modified oral rental             
          arrangement represented fair market rents.                                  
               JJ & P Farms, Inc., filed Form 1120, U.S. Corporation Income           
          Tax Return, for its taxable year 1995 (JJ & P Farms, Inc.’s 1995            
          return).  In JJ & P Farms, Inc.’s 1995 return, JJ & P Farms,                
          Inc., reported that it paid $17,439 of compensation to Mr. Solvie           
          as an officer of that company and $3,410 of compensation to Ms.             
          Solvie as an officer.  In that return, JJ & P Farms, Inc.,                  
          reported that it paid $6,989 of salaries and wages, although it             
          did not identify in that return the person or persons to whom it            
          paid those wages.  In JJ & P Farms, Inc.’s 1995 return, JJ & P              
          Farms, Inc., reported that it paid $142,634 in rent, although it            
          did not specify in that return the amount of such rent that it              
          paid to petitioners during its taxable year 1995.                           
               On March 20, 1998, respondent issued a notice to petitioners           
          with respect to their taxable years 1993, 1994, and 1995.  In               
          that notice, respondent determined that the 1993 claimed rent,              
          the 1994 claimed rent, and the 1995 total claimed rent, reduced             
          by the deductions attributable to such respective rents, are                
          subject to self-employment tax because they constitute net                  
          earnings from self-employment under section 1402(a)(1).                     






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