Oliver E. Stubblefield - Page 8

                                   - NEXTRECORD  -                                    
               Petitioner earned approximately $2,900 in 1988 working as an           
          employee for Amoco and Tenneco, which amount he reported on an              
          income tax return for that year.  Petitioner did not report                 
          income from any other source for that year.                                 
               Petitioner filed an income tax return for 1990 and reported            
          thereon approximately the same amount of income that he reported            
          on his income tax return for 1991.  See infra, next topic.                  
          Petitioner's Income Tax Return for 1991                                     
               Petitioner filed an income tax return (Form 1040) for 1991,            
          the taxable year in issue.  On his return, petitioner reported              
          total income of $4,150.  This amount consisted of interest income           
          of $100 and business income of $4,050.  On his return, petitioner           
          identified his occupation as "barber".                                      
               Petitioner attached a Schedule C (Profit or Loss From                  
          Business) to his 1991 return.  On the Schedule C, petitioner                
          reported gross receipts of $4,500, total expenses of $450, and              
          net profit of $4,050.  On his Schedule C, petitioner identified             
          his principal business as "haircutting".                                    
               Petitioner reported "zero" taxable income, and therefore no            
          "regular" income tax under section 1, on his 1991 return.  He did           
          report self-employment tax under section 1401 based on the net              
          profit disclosed on his Schedule C.4                                        

          4 Although petitioner reported "zero" taxable income, his                   
          return actually disclosed a loss of $1,400.  Because petitioner             
          did not claim any deduction under sec. 164(f) for one-half of his           
                                                             (continued...)           




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