Gerard and Audrey Kathleen Hennessey - Page 12




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               On December 30, 1996, petitioners filed with the IRS a Form            
          1040 for the 1995 taxable year (1995 return).  On the 1995                  
          return, petitioners reported adjusted gross income of $25,439 and           
          an NOL carryforward of $50,132.  Petitioners claimed deductions             
          for travel expenses of $9,428 and $21,565 on Form 2106 and                  
          Schedule C, respectively.  Petitioners again claimed multiple               
          deductions for some of the same expenses.                                   
               On or about March 14, 1997, respondent received a second               
          Form 1040 from petitioners for the taxable year 1995 with                   
          “Amended” written at the top of the first page (1995 “Amended”              
          return).  On the 1995 “Amended” return, petitioners reported                
          adjusted gross income of $6,395.  Petitioners also reported                 
          deductions for travel expenses of $14,586 on both the Form 2106             
          and Schedule C.                                                             
               On or about August 18, 1997, respondent received a Form 1040           
          from petitioners for the 1996 taxable year.  On the 1996 return,            
          petitioners reported adjusted gross income of $16,529 and an NOL            
          carryforward of $36,157.  On a Schedule A, Itemized Deductions,             
          petitioners claimed a deduction for “Job travel: accom. in                  
          Dallas” in the amount of $59,479.  Petitioners also claimed a               
          deduction for travel expenses on Form 2106 of $36,714.  On the              
          Schedule C for ISOA Consulting attached to the 1996 return,                 









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