- 17 -
writing, to sort the materials by year, by whether the item was
income or expense, and (as to expenses) by type.' Petitioner took
the boxes back when he left Burns' office. At the second
interview, on October 31, 1989, petitioner brought sorted but
incomplete records, but only for 1985. The 1985 records were
mostly bank records. Petitioner did not provide any other
records to respondent before the notice of deficiency was sent.
On each of his tax returns for the period 1982 through 1986,
petitioner's only stated occupation is "Attorney", except that he
also shows farm income on his 1982 tax return.
For each of these years, petitioner claims either a negative
adjusted gross income or a loss carryforward, and shows no tax
liability. Petitioner does not itemize deductions on any of
these tax returns. Petitioner does not show any liability for
self-employment taxes on any of these tax returns.
Income
On his tax returns, petitioner reports income or gross
receipts in the amounts shown in table 3.
Table 3
Category 1982 1983 1984 1985 1986
Wages, etc. $46,943 $26,400 $24,000 -0- -0-
Interest 4,187 –- 12,304 2$100 2$10
Sched. C
(gross rcpts) – 1,095 21,000 313,448 23,565
Capital gain 8,207 21,600 -0- 40,000 --
Royalties 14,318 33,599 37,979 21,641 212,500
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