Miriam Lawrence - Page 5

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            with Abraham in the amount of $39,969.  In addition, on a                                     
            Schedule C she reported $3,453 in gross receipts from her other                               
            businesses.  After various deductions she reported taxable income                             
            of $8,193 for the year 1986.                                                                  
                  Her 1987 Federal income tax return was apparently timely                                
            filed.  For that year she reported $39,847 in salary from her                                 
            employment with Abraham, and on a Schedule C, $8,743 in gross                                 
            receipts from her other businesses.  After various deductions she                             
            reported taxable income of $18,617 for the year 1987.                                         
                  As best we can tell from the record, there was nothing on                               
            Lawrence's returns that indicated that she was indebted to                                    
            Abraham during the years 1986 and 1987.                                                       
                  B. Joseph and Margaret Abraham                                                          
                  On a Schedule C included with the Abrahams' 1987 Federal                                
            income tax return, Abraham reported gross receipts in the amount                              
            of $1,344,364 from his law practice.  Although there is some                                  
            information with respect to specific expenses deducted on the                                 
            Schedule C, the record does not reveal whether petitioners                                    
            reported a net profit or loss from Abraham's practice of law.  We                             
            are unsure as to the extent, nature, or source of other income                                
            that might have been reported on their return.  It appears that                               
            the Abrahams elected to itemize deductions for the year 1987.  On                             









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