- 3 - 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.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