Wayne B. Bailey - Page 6




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               At several stages in petitioner’s career as a businessman              
          and consultant, petitioner was exposed to the food and drink                
          franchise industry and worked with some of the largest franchise            
          operators in the world, including McDonald’s Corporation.                   
          Petitioner also earned a master’s degree in business                        
          administration with a concentration in marketing and finance from           
          the University of Chicago in 1989.                                          
               On his Form 1040 for 2001, petitioner reported wages of                
          $217,771.  Petitioner attached a Schedule C to his Form 1040 for            
          2001.  On his Schedule C for 2001, petitioner claimed business              
          deductions of $55,348, zero gross receipts or sales, and other              
          income of $161.  On the Schedule C for 2001, petitioner reported            
          the business name as “Tasha’s” and the principal business or                
          profession as “Retail”.                                                     
               On his Form 1040 for 2002, petitioner reported wages of                
          $188,468.  Petitioner attached a Schedule C to his 2002 income              
          tax return, reporting $48,001 of business deductions, zero gross            
          receipts or sales, and other income of $43.  On the Schedule C              
          for 2002, petitioner reported the business name as “Tasha’s” and            
          the principal business or profession as “Wine Distribution/                 
          Retail”.                                                                    
               On June 8, 2005, respondent sent petitioner the above-                 
          mentioned notice of deficiency.  Respondent attached to the                 
          notice of deficiency copies of Form 4549A, Income Tax Examination           







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