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name of TEL Sickle Cell Research & Development and attempted to
obtain tax-exempt status from the Internal Revenue Service
under section 501(c)(3). That attempt was unsuccessful and was
not pursued further. Petitioner, nevertheless, continued with
his laboratory and considered it a trade or business for tax
purposes for the years at issue.
On their 1991 and 1992 income tax returns, petitioners
reported their construction/laboratory activity on Schedule C,
Profit or Loss From Business, as follows:
1991
Income -0-
Expenses:
Bad debts from sales or services $22,360.00
Car and truck expenses 1,034.74
Insurance 3,849.00
Legal and professional services 8,494.71
Office expense 637.00
Rent or lease of vehicles 2,640.00
Utilities 4,080.00
Total $43,095.45
Loss $43,095.45
1992
Income -0-
Expenses:
Advertising $ 3,840
Commissions and fees 2,130
Insurance 1,560
Legal and professional services 2,500
Office expense 632
Rent or lease of vehicles 547
Repairs and maintenance 18,350
Taxes and licenses 680
Travel 1,303
Meals and entertainment (net) 294
Utilities 2,880
Total $34,716
Loss $34,716
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Last modified: May 25, 2011