- 8 -
abandoned this argument. See Mendes v. Commissioner, 121 T.C. at
312-313.
Further, even though Ahmed now argues that he should not be
liable for self-employment taxes, on the initial computations
that Ahmed submitted to the Court, Ahmed himself calculated self-
employment taxes on the collapsed income.
Crediting of Nominee Payments for Purposes of Determining the
Penalty and Additions to Tax for 1997 and 1998
In calculating Ahmed’s 1997 and 1998 penalty and additions
to tax, neither party in the initial Rule 155 computations
credited Ahmed for the nominee corporations’ 1997 and 1998 income
tax payments.
We conclude that because Ahmed is being charged with the
nominee corporations’ income and expenses, in calculating Ahmed’s
1997 and 1998 penalty and additions to tax, it is appropriate to
credit Ahmed individually with the amounts paid by the nominee
corporations as Federal income taxes for each year. Ahmed is to
be so credited.5
5 In calculating Ahmed’s 1997 sec. 6651(a)(1) and 1998 sec.
6651(f) additions to tax, Ahmed is to be credited only with those
payments made by the nominee corporations prior to the due dates
of Ahmed’s respective Federal income tax returns. See sec.
6651(b)(1).
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Last modified: May 25, 2011