Gerard and Audrey Kathleen Hennessey - Page 13




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          petitioners reported gross income of $38,220 and total expenses             
          of $38,220.  On the 1996 return, petitioners claimed multiple               
          deductions for some of the same expenses.                                   
               B.  Beacon’s Tax Returns                                               
               On or about August 12, 1994, Beacon submitted an “Estimated”           
          Form 1120S, U.S. Income Tax Return for an S Corporation, for the            
          taxable year 1993 (Beacon’s 1993 “Estimated” return) along with             
          petitioners’ 1993 “Estimated” return.  Beacon’s 1993 “Estimated”            
          return reflected that Beacon was on the cash receipts and                   
          disbursements method of accounting (cash basis) for Federal                 
          income tax purposes.6                                                       
               On or about March 4, 1997, Beacon filed with the IRS a                 
          second Form 1120S for the taxable year 1993 (Beacon’s 1993                  
          return).  Beacon’s 1993 return reported total income and total              
          deductions of $13,691 and $24,248, respectively, for a loss of              
          $10,557.  Beacon’s total deductions included travel expenses of             
          $13,717.                                                                    
               Along with petitioners’ 1994 “Estimated” return, Beacon                
          submitted for the taxable year 1994 a Form 1120S with “Estimated”           
          written on the top of the first page (Beacon’s 1994 “Estimated”             
          return).  Beacon’s 1994 “Estimated” return reported total income            
          and total deductions of $5,000 and $2,710, respectively.                    


               6 At all relevant times during the years in issue, Beacon              
          used the cash basis method of accounting for Federal income tax             
          purposes.                                                                   





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