-434- 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.Page: Previous 424 425 426 427 428 429 430 431 432 433 434 435 436 437 438 439 440 441 442 443 Next
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