- 16 -
of $9,100 were made by petitioner and that for 1990 $4,908 of tax
was withheld from petitioner and $4,135 of tax was paid with his
1990 application for automatic extension.
Petitioner filed returns for 1989 and 1990 that were dated
August 14, 1990, and October 25, 1991, respectively, were re-
ceived by the Internal Revenue Service (Service) on August 23,
1990, and November 1, 1991, respectively, and showed total tax
liabilities of $9,043 and $15,716, respectively.8
Petitioner took account of the following items to arrive at
the adjusted gross income of $61,892, $95,024, and $152,576 shown
in his respective returns for 1989, 1990, and 1991:
1989 1990 1991
Wages, salaries, etc. $14,923 $49,000 $86,500
Taxable interest 1,956 982 441
Dividends 55 947 1,720
Tax refunds -- 1,315 --
Schedules C
Net profit from
art sales 99,0009 -- --
Loss from commodities
and other investments 2,925 -- --
1989 1990 1991
Loss for 1989 and net
profit for 1990 from
the New Life Center 44,375 32,718 --
8 All dollar amounts are rounded to the nearest dollar.
9 In Schedule C of his 1989 return relating to art sales, peti-
tioner reported $100,000 as "Gross receipts or sales", $1,000 as
"Cost of goods sold and/or operations", and $99,000 as "Net
profit" with respect to the sale of the drawing in question.
Petitioner concedes that he sold that drawing for $115,000,
purchased it for $1,300, and realized a gain of $113,700 from its
sale.
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