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Issue XXII. Whether Kanter Is Liable for Self-Employment
Tax for 1982 (STJ report at 180-181)167
OPINION
Respondent determined in the notice of deficiency for 1982
that Kanter is liable for additional self-employment tax of $848.
Inasmuch as respondent’s determination turns on the disposition
of other adjustments respondent determined for 1982, the amount
of Kanter’s self-employment tax will be determined in the
parties’ computations for entry of decision pursuant to Rule 155.
Issue XXIII. Whether the Kanters Realized Capital Gains and
Losses as Reported on Their 1987 Tax Return
(STJ report at 182-198)
Respondent determined in the notice of deficiency issued to
the Kanters for 1987 that they were not entitled to capital
losses arising from various sales of stocks, bonds, promissory
notes, and partnership interests to Mallin, MAF, Inc., Windy
City, Inc., and others. These adjustments were resolved against
petitioners and the decision entered by the Court at docket No.
24002-91 for the taxable year 1987 on September 24, 2001, was not
167 The STJ report recommended alternative holdings that
turned on whether the self-employment tax issue was inadvertently
omitted from the parties’ stipulated settlement. If so, the STJ
report proposed to hold for petitioners. On the other hand, if
the matter was purely computational, the matter would be
addressed in the parties’ Rule 155 computations. The Court
concludes, on the basis of the manner in which the issue is set
forth in the notice of deficiency, that this issue is purely
computational.
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