Janice L. Morris - Page 20

                                       - 20 -                                         
          that was shown in the respective Forms 1120S that Accu-Data and             
          Meadows, S corporations, filed for those years.20  In Schedule E            
          of the joint return for each of the years 1988 and 1989, they               
          reported aggregate income from Accu-Data and Meadows of $24,929             
          and $18,987, respectively.                                                  
               No income attributable to Accu-Data was reflected in the               
          joint return for 1987, and no income attributable to MCIC or                
          Trust 768 was reflected in the joint return for any of the years            
          at issue.                                                                   
               Mr. Morris received Forms W-2 (Wage and Tax Statement) from            
          John Kenny Company and Douglas Water Co. for each of the years at           
          issue that were attached to the joint returns for those years and           
          that showed the following:                                                  
















          20  Although petitioner and Mr. Morris included in Schedule E of            
          their joint return for 1989 only $19,112 of income from Meadows,            
          the Form 1120S filed by Meadows for that year reflected $29,112             
          of income.                                                                  




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