Homer L. Richardson - Page 47

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          description of the gift; (3) the business purpose of the                    
          expenditure or use; and (4) in the case of entertainment or                 
          gifts, the business relationship to the taxpayer of the                     
          recipients or persons entertained.  Sec. 274(d).                            
               On this issue, petitioners neither at trial nor on brief               
          offered evidence or argument directed towards the deductibility             
          of any of the specific expenses disallowed by respondent.                   
          Respondent’s determinations therefore are sustained as to those             
          adjustments.13                                                              
               In addition, respondent determined that petitioners were               
          liable for self-employment taxes, and entitled to corresponding             
          self-employment tax deductions, on business income attributed to            
          them from HGAMC in 1996 and 1997.  Section 1401 imposes an                  
          additional tax on the self-employment income of every individual,           
          both for old age, survivors, and disability insurance and for               
          hospital insurance.  The term “self-employment income” denotes              
          “net earnings from self-employment”.  Sec. 1402(b).  “Net                   
          earnings from self-employment”, in turn, means “the gross income            
          derived by an individual from any trade or business carried on by           
          such individual, less the deductions allowed by this subtitle               
          which are attributable to such trade or business”.  Sec. 1402(a).           

               13 The Court further notes that although petitioners would             
          generally be entitled to deduct substantiated charitable                    
          contributions on their personal returns in accordance with our              
          disregard of the trusts, all donations by HGRCT were made in                
          calendar year 1998 or thereafter.  Petitioners are calendar year            
          taxpayers, and the years before the Court are 1996 and 1997.                




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