John Van Heemst - Page 6

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          Michael Van Heemst reflecting the income of Pieces of Eight.                
          Petitioner provided Mr. Louwers with the information concerning             
          Pieces of Eight that was used for purposes of preparing financial           
          statements and tax returns.                                                 
               For taxable year 1987, petitioner filed a joint Federal                
          individual income tax return (1987 return) with Ms. Murphy.3  On            
          the 1987 return, petitioner and Ms. Murphy reported income from             
          the sources and in the amounts shown below:                                 
          Source                                Amount                                
          Form W-2 wages (Ms. Murphy)                  $10,000                        
          Form W-2 wages (petitioner)                   10,000                        
          Taxable interest income                          478                        
          Nonpassive income from S corporation                                        
          (Pieces of Eight Dive Center, Inc.)            411                          
          Total income reported per return         20,889                             
          The Forms W-2 for both petitioner and Ms. Murphy indicate as                
          employer "Kathleen Murphy, Pieces of Eight, PO Box 1124, Captiva,           
          Fl 33924".                                                                  
               Petitioner and Ms. Murphy claimed one personal exemption for           
          each of themselves and a dependency exemption for petitioner's              
          17-year-old son, Jason, who lived with them.  Additionally, they            
          claimed itemized deductions on Schedule A in the amounts shown              
          below:                                                                      

          3                                                                           
               The notice of deficiency for 1987 was issued to both                   
          petitioner and Ms. Murphy.  She did not file a petition with                
          respect to that notice and, accordingly, is not a party to the              
          instant case.                                                               





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