Wilburn C. Hall, Jr. - Page 17

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          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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