Frank R. Courbois - Page 5

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                      Over the years, petitioner has built two sailboats.                                
                One was a 24-foot sailboat which petitioner sold.  There                                 
                is no information in the record concerning the costs                                     
                petitioner incurred in building the 24-foot sailboat or                                  
                the price for which petitioner ultimately sold the boat.                                 
                Petitioner also built a 33-foot sailboat.  As of the time                                
                of trial, petitioner still owned the 33-foot sailboat, and                               
                he used it for recreational purposes.                                                    
                      In summary, petitioner reported the following adjusted                             
                gross income on his Form 1040, U.S. Individual Income Tax                                
                Return for 1990:                                                                         

                      Interest income                                 $29                               
                      Business income (Schedule C)               78,253                                  
                      Capital gain (Schedule D)                  71,683                                  
                      Other gains or (losses) (Form 4797)    3,612                                       
                      Rents, royalties, partnerships,                                                    
                      estates, trusts, etc. (Schedule E)  (78,751)                                       
                      Total adjustments                           (5,925)                               
                            Adjusted gross income                68,901                                  

                      The above business income consists of the net profit                               
                from petitioner's law practice as reported on the Schedule                               
                C, Profit or Loss from Business, attached to petitioner's                                
                1990 tax return, as follows:                                                             

                                  Gross income                   $157,391                                
                                  Total expenses                  79,138                                 
                                  Net profit (loss)              78,253                                  





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