-3-
incorporated herein by this reference. Petitioner resided in
Chicago, Illinois, at the time he filed his petition.
Background
Petitioner is a certified public account who attended
Northern Illinois University in the early 1970's, earning
sufficient credits to have a major in art and minor in
accounting, although he did not graduate. From 1978 until the
present, petitioner has been employed in various positions
utilizing his accounting background.
In 1984, petitioner began his own accounting practice as a
sole proprietor, operating out of rented space on the first floor
of the building in which he lives. Petitioner has reported the
results of his accounting business on Schedule C of his Federal
income tax returns, although he has not filed a return every
year. For each of the years at issue, the net profit from
petitioner's accounting business is as follows:
Year Net Profit
1988 $9,518
1989 16,824
1990 19,977
1991 26,930
At the same time that he began his accounting business,
petitioner also began to develop himself as an artist. Indeed,
petitioner's purpose in leaving his former employer was to use
the accounting business to "pay the rent" while at the same time
devoting more effort to his artistic endeavors. Petitioner has
reported the results of his artist activity on a separate
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