- 21 -
petitioners invested in a shopping mall called the Holt
Shopping Center. Petitioners did not create a formal
business plan or cost analysis prior to investing in this
venture. Petitioners reported the following income from
their investment in the shopping center during the years
in issue:
Year Total Income Miscellaneous Income
1987 $17,359 $2,400
1988 21,835 2,200
1989 16,440 2,600
1990 17,205 2,400
1991 18,156 2,400
Petitioners also invested in residential property in
Florida, including a "tennis villa" and a "resort villa".
The record does not disclose the precise nature of these
investments or the income or loss realized from them.
Sometime in 1990, Mrs. Holmes opened a retail
clothing business. Petitioners reported a loss from this
business in the amount of $584 in 1990 and a profit of $179
in 1991.
Petitioners' Bookkeeping Practices
Virtually all of petitioners' business and investment
activities, including the tennis villa and the resort
villa, were conducted through RC. In 1990, pursuant to
Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 NextLast modified: May 25, 2011