James S Sparkman - Page 3

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               Unless otherwise indicated, section references are to the              
          Internal Revenue Code, as amended.  Rule references are to the              
          Tax Court Rules of Practice and Procedure.                                  
               After concessions by respondent, the issues for decision in            
          these consolidated cases are:  (1) Whether Mercury Solar PTO                
          should be disregarded as an entity separate from Sparkman for               
          Federal tax purposes and its net income attributed to Sparkman              
          for the years at issue; (2) whether in 1999 Mercury Solar PTO               
          (and hence Sparkman) had unreported income resulting from certain           
          rebate payments from Hawaii Electric Company (HECO); (3) whether            
          for the years at issue Sparkman is liable for self-employment tax           
          on his earnings from Mercury Solar PTO;2 (4) whether for the                
          years at issue Sparkman is entitled to claimed losses from a                
          purported business trust, Hawaii Environmental Holdings (HEH);              
          (5) whether Sparkman is entitled to additional itemized                     
          deductions, allegedly not claimed on his Federal income tax                 
          returns, for interest or charitable contributions; and (6)                  






               2 The amount of Sparkman’s liability for self-employment               
          taxes and the amount of the related deduction under sec. 164(f)             
          to which Sparkman is entitled are computational matters.                    
          Resolution of these issues depends upon our resolution of the               
          issue whether Mercury Solar PTO should be recognized as an entity           
          separate from Sparkman.  Petitioners have not separately                    
          challenged such liability, and we do not further discuss these              
          items.                                                                      




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Last modified: May 25, 2011