Legal Opinion

Charlton v. Commissioner

United States Tax Court

Decided May 16, 2000No. 11412-98; No. 11861-98PublishedCited by 50 opinions

Ps were married in 1989, separated in 1995, and divorced in 1996. In 1994, W operated Medi-Task, a physician's transcription business. H was employed full time by a large corporation until September 1994. In the fall of 1994, he moved to a lake and began to renovate some rental cabins. Ps filed a joint tax return for 1994 in which they reported that they had self- employment tax liability for the transcription business and deducted rental cabin expenses.

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Ps were married in 1989, separated in 1995, and divorced in 1996. In 1994, W operated Medi-Task, a physician's transcription business. H was employed full time by a large corporation until September 1994. In the fall of 1994, he moved to a lake and began to renovate some rental cabins. Ps filed a joint tax return for 1994 in which they reported that they had self- employment tax liability for the transcription business and deducted rental cabin expenses. R determined a deficiency based in part on adjustments to Ps' self-employment tax and denial of deductions relating to the cabins. Ps filed…

1Opinion of the Court

Colvin, Judge:

Respondent determined that, for 1994, petitioners were liable for a $15,192 deficiency in income tax and a $1,731 accuracy-related penalty under section 6662(a).

Following concessions,1 the issues for decision are:(1) Whether all of petitioners’ self-employment income from Medi-Task is allocated to petitioner Sarah K. Hawthorne (Hawthorne) for purposes of computing self-employment tax for 1994. We hold that it is.(2) Whether petitioners may deduct expenses relating to their rental cabins in 1994. We hold that they may not.(3) Whether petitioner Fredie Lynn Charlton (Charlton) is…

2Cases cited2 opinions

  1. BUTLER v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2000
  2. McCoy v. CommissionerUnited States Tax Court · 1972

3Cited by50 opinions

  1. Cheshire v. CommissionerUnited States Tax Court · 2000
  2. Porter v. Comm'rUnited States Tax Court · 2009
  3. Corson v. CommissionerUnited States Tax Court · 2000
  4. King v. CommissionerUnited States Tax Court · 2000
  5. VETRANO v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001

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