- 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 21,641 212,500Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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