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concessions,2 the issues for decision are: (1) Whether
petitioner is entitled to deduct on Schedule C, Profit or Loss
From Business, expenses in an amount greater than determined by
respondent; and (2) whether petitioner is liable for self-
employment tax.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time he filed his
petition, petitioner resided in San Bruno, California.
During 2001, petitioner operated Sam Transportation, a
transportation company. Petitioner’s sister and brother-in-law
also participated in Sam Transportation.
Petitioner timely filed his 2001 Federal income tax return,
reporting adjusted gross income of $9,211 and total tax of $377.
Petitioner did not report any items from the operation of Sam
Transportation on his tax return.
2 The parties agree that petitioner: Correctly reported
gross receipts of $403,845 on his Schedule C, Profit or Loss From
Business; is entitled to a deduction of $1,142 for self-
employment health insurance; and, pursuant to sec. 164(f), is
entitled to a self-employment tax deduction of one-half of the
self-employment tax imposed by sec. 1401. The amount of the
self-employment tax deduction, as well as petitioner’s personal
exemption and a rate reduction credit, are computational matters
that the parties shall resolve as part of their Rule 155
computations.
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Last modified: November 10, 2007