Eric A. and Jane C. Lanigan - Page 5

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            revised or completed by the IRS representative (revised returns).                             
            For each year what is described as the original return and what                               
            is described as the revised return is the same document; i.e.,                                
            the Form 1040 signed by petitioners and filed with the IRS on                                 
            October 19, 1992:                                                                             
            Taxable Year 1990                                                                             
                  Form W-2                   $ 60,263.40                                                  
                  Forms 1099                    83,262.91                                                 
                  Total Comp.                $143,526.31                                                  
                                           Original Return                Revised Return                  
                  Wages                     1 $144,707.23                   $     0.00                    
                  Interest                          285.48                       285.48                   
                  Business Income              (45,472.50)                    97,974.87                   
                  Total                      $ 99,520.21                    $98,260.35                    
                  Adj. Gross Inc.           2 $ 99,519.98                   $98,260.35                    
                  Sched. C                                                                                
                  Gross Receipts              $                           4 $143,437.37                   
                  Total Expenses              3 (45,472.50)                 (45,462.50)                   
                        Net Profit           $                             $ 97,974.87                    

                  1The record does not explain the source of this $144,707.23                             
                  figure that petitioner placed on the return.                                            
                  2This figure is $.23 less than the above figure; there is no                            
                  explanation for this discrepancy.                                                       
                  3Petitioner partially filled out one Schedule C with the                                
                  total expenses as indicated here; the correct total of the                              
                  listed expenses is $45,462.50.  On that Schedule C, gross                               
                  receipts was listed as $83,173.97 and net profit as                                     
                  $37,711.47.  It is uncertain who wrote in these figures.                                
                  The IRS representative completed a second Schedule C showing                            
                  gross receipts of $60,263.40 (the W-2 income) and zero                                  
                  expenses.  We note that the $83,173.97 is exactly $88.94                                
                  less than the nonemployee compensation shown on the Forms                               
                  1099 attached to the return as filed with the IRS.                                      
                  4This figure represents the combined gross receipts on the                              
                  two Schedules C:  $60,263.40 of W-2 wage income and                                     




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