Donald D. Bowers and Deborah Bowers - Page 25

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            Tax Return                                                                                 
                  Petitioners requested and received approval of their                                 
            Application for Additional Extension of Time To File their 1989                            
            Federal income tax return until October 15, 1990.  The dates                               
            appearing next to petitioners' signatures on the return are both                           
            November 4, 1990.  The Internal Revenue Service (IRS) received                             
            the return on November 13, 1990.                                                           
                  Petitioners reported an adjusted gross income of $32,856,                            
            which consisted of Mr. Bowers' wages from TAI of $27,600,                                  
            Schedule E income from TAI of $4,929, and $327 from Deborah's                              
            modeling.  Petitioners reported no income from any of Mr. Bowers'                          
            other business interests.  Mr. Bowers' Form W-2 from TAI shows                             
            his address as that of the Mandarin house.                                                 
                  Petitioners completed Form 2119 (Sale of Your Home) and                              
            attached it to their return.  On this form, petitioners reported                           
            the sale of the Burlington property for $320,000, an adjusted                              
            basis in that property of $182,634, and a gain of $137,366.                                
            Petitioners did not indicate any fixing-up expenses on the                                 
            Burlington house, nor any selling expenses.  They reported the                             
            cost of a new residence as $370,273.                                                       
                  The IRS examined petitioners' return and disallowed the                              
            deferral of gain from the sale of the Burlington property on the                           
            ground that petitioners had not shown that they used the                                   

            moved to Florida, let alone Mr. Bowers.                                                    

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