Legal Opinion
Bobo v. Commissioner
United States Tax Court
Decided August 17, 1978No. Docket No. 11209-76PublishedCited by 5 opinions
Held, net rental income from petitioners' mobile home park not subject to self-employment tax under sec. 1401, I.R.C. 1954.
1Opinion of the Court
Wiles, Judge:
Respondent determined deficiencies of $864.00 and $1,042.80 in petitioners’ 1973 and 1974 Federal income taxes. The sole issue is whether petitioners’ net rental income from their mobile home park is subject to self-employment tax under section 1402(a)(1).1
FINDINGS OF FACT
Some facts are stipulated and are found accordingly.
Fabian and Florence Bobo, husband and wife, were legal residents of Novato, Calif., when they timely filed their 1973 and 1974 returns with the Internal Revenue Service Center, Fresno, Calif., and when they filed their petition in this case.
Petitioners own a…
2Cases cited2 opinions
- George F. Delno v. Anthony J. Celebrezze, Secretary of Health, Education and WelfareCourt of Appeals for the Ninth Circuit · 1965
- Johnson v. CommissionerUnited States Tax Court · 1973
3Cited by5 opinions
- Hopper v. CommissionerUnited States Tax Court · 1990
- Bobo v. CommissionerUnited States Tax Court · 1978
- Cinelli v. CommissionerUnited States Tax Court · 1991
- Hopper v. CommissionerUnited States Tax Court · 1990
- Stover v. CommissionerUnited States Tax Court · 1984