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Hayward consisted primarily of "prospecting" in the years here in
issue. Petitioner considers that when an insurance agent meets
potential clients who are willing to speak about insurance, the
agent is "prospecting". Petitioner's "prospecting" activities in
the Hayward area consisted of going to dinner, playing golf at
the Tagalong Country Club, and having drinks with persons he
considered potential clients.
For the taxable year 1987, petitioner reported gross
receipts in the amount of $6,795 from his insurance business, of
which $2,249 was identified as related to business in Hayward,
Wisconsin. For the taxable year 1988, petitioner reported gross
receipts in the amount of $5,803, none of which was identified on
the return as relating to business in Hayward.
Petitioner deducted expenses that he claimed as related to
his insurance business in Hayward on both Schedule C, Profit (and
Loss) from Business or Profession, and Form 2106, Employee
Business Expenses, of his Federal income tax return for each of
the taxable years 1987 and 1988.
On August 7, 1984, petitioners purchased a condominium that
was located approximately 14 miles southwest of Hayward (the
condominium) for $39,417. The condominium was a three-bedroom
unit. For the taxable years 1984 through 1986, petitioners, on
Schedule E of their Federal income tax returns, deducted expenses
connected with the condominium, listing it as rental property.
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