Dudley Joseph and Myrna Dupuy Callahan - Page 5

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          assignments, and sought financial assistance for her writing                
          endeavors.  In 1994 she acquired a local occupational license "to           
          pursue and follow the Occupation of wholesale retail."                      
          Petitioner self-publishes her manuals on a prepaid basis only for           
          $10.00 each, plus $1.00 for postage and handling.  Her manuals              
          have been listed on two databases compiled by R.R. Bowker Company           
          (Bowker), Literary Market Place:  A Directory of American Book              
          Publishers and Books in Print.                                              
               The gross receipts, gross income, expenses, and losses                 
          attributed to $'s Info Books and as reported by petitioners on              
          their Forms 1040, Schedules C for taxable years 1987 through 1992           
          are summarized as follows:                                                  
                         Gross          Gross                                         
               Year      Receipts       Income    Expenses        Losses              
               1987      $80            $80       $6,061         $(5,981)             
               1988      -0-            3         6,333          (6,330)              
               1989      -0-            33        13,059         (13,026)             
               1990      134            124       23,287         (23,163)             
               1991      -0-            27        21,641         (21,614)             
               1992        432           (68)      25,411        (25,343)             
               Total       646           199       95,792        (95,457)             
          The principal source of petitioners' receipts reported on                   
          Schedules C for 1987-1992 was prizes and sweepstakes winnings.              
          Among the sources of petitioners' reported Schedule C losses were           
          deductions for depreciation of an electric screwdriver and a                
          weedwacker.  Their Schedules C losses contributed to petitioners'           
          receiving full tax refunds for 1989, 1990, and 1991.                        








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