James H. Shelton, Deceased, and Eve Shelton - Page 4

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          on the Schedule C.  Petitioner's records do not indicate to whom,                  
          or how many copies of his book were sold.                                          
                Independent from his employment at Sierra, from January to                   
          September of 1992, petitioner conducted educational seminars on                    
          the mathematics of electronics.  The seminars were held 5 days                     
          per week for 4 hours per day.  He taught between 3 and 6 students                  
          at any given time.                                                                 
                During January and February of 1992, petitioner used an                      
          empty room located in an airport as his seminar classroom.                         
          Petitioner sublet this room from Webaire.  Due to complications                    
          involving his arrangement with Webaire, beginning in March of                      
          1992, petitioner rented a different room at the airport directly                   
          from the Port of Oakland.  He used this room as his seminar                        
          classroom for the rest of the year.  The airport was located less                  
          than one block from Sierra.  Petitioner drove a pickup truck from                  
          his residence to Sierra and then walked from Sierra to the                         
          airport.                                                                           
                Petitioners filed a Schedule C for petitioner's "education                   
          business" with their 1992 Federal income tax return.  On the                       
          Schedule C, among other things, petitioners reflected gross                        
          receipts in the amount of $7,271.  Apparently $124 of this amount                  
          is attributable to the sales of his book, and a substantial                        
          portion of the balance is attributable to the fees he charged for                  








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