Eddie M. and Cynthia L. Chandler - Page 3

                                   - NEXTRECORD  -                                    
          deduction under section 164(f) to which they are entitled for               
          1990) and whether petitioners are entitled to an earned income              
          credit for 1990 are derivative issues, the resolution of which              
          depends on our disposition of the second issue enumerated above.            
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and they are so                
          found.  Petitioners resided in Piedmont, Alabama, at the time               
          that their petition was filed with the Court.                               
               For 1989 and 1990, the taxable years in issue, petitioners             
          were married and filed joint income tax returns.  They have three           
          children, two sons and a daughter, who were born in 1985, 1986,             
          and 1987.                                                                   
               In 1989 and for a short period in 1990, petitioner Eddie M.            
          Chandler (petitioner) was employed as a rubber worker by Goodyear           
          Tire and Rubber Company (Goodyear).  Petitioner terminated                  
          employment with Goodyear in 1990.                                           
               Petitioner was also self-employed in 1990.  He reported                
          income from three separate activities: bulldozer work and                   
          digging; sales of wood products; and sales of melons.                       
               Petitioner also derived income in 1990 from the sale of                
          marijuana.  Petitioner had "played" with marijuana for many years           
          before 1990.  Petitioners did not report any income from the sale           
          of marijuana on either of their income tax returns for the years            
          in issue.                                                                   






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