Paul M. and June S. Sengpiehl - Page 4

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               Petitioners' home had one telephone line with extensions in            
          the kitchen, master bedroom, and in each of the enclosed porches.           
          Petitioners' phone number was listed in the residential section             
          of the Illinois Bell Telephone Directory and in Sullivan's Law              
          Directory under petitioner's name.  Petitioners paid telephone              
          expenses in the amount of $1,004 in 1991.                                   
               Petitioners' son, Jeffrey Sengpiehl, and daughter, Chrystal            
          Sengpiehl, resided with petitioners for part of the year in                 
          issue.  Chrystal Sengpiehl lived in their home through the end of           
          August 1991, at which time she left to attend college.  Jeffrey             
          Sengpiehl married in November 1991, at which time he moved from             
          petitioners' home.  Jeffrey Sengpiehl and his wife filed a joint            
          tax return Form 1040 for the tax year 1991 and reported income in           
          the amount of $13,351.87.                                                   
               On Schedule C of their 1991 Federal income tax return,                 
          petitioners reported gross receipts from petitioner’s legal                 
          practice in the amount of $50,179.62.  On Schedule C, petitioners           
          claimed a deduction for home office expense in the amount of                
          $4,143 based upon business usage of 41.67 percent of their home.            
          Petitioners also claimed a deduction for other expenses in the              
          amount of $6,895, including telephone expense in the amount of              
          $1,004.  On their 1991 return, petitioners claimed a dependency             
          exemption deduction with respect to both Chrystal and Jeffrey.              
          Petitioners also claimed an earned income credit for 1991.                  






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