-10- Mrs. Marzullo prepared all invoices and kept track of whether checks in payment of the invoices had been received. If an invoice was not paid, she would contact the customer concerning payment. When checks were received, she gave them to Mr. Marzullo, who deposited the checks, paid the bills, and kept a record of income and expenses. His participation in the business was essentially clerical. Mrs. Marzullo sometimes made corrections to Mr. Marzullo's records. Mr. Marzullo did not deal with customers and had no knowledge of the video production business. Petitioners used their personal checking account for MPM's business checks and deposits. MPM was operated from petitioners' residence, and the business paid no salary or commissions. Mrs. Marzullo obtained a business phone number, corporate stationery, and business cards. MPM elected S corporation status. It filed a Form 1120S return for the period September 1 to December 31, 1987, but in 1988 petitioners filed a Schedule C reporting MPM's activities with their return. Petitioners' Form 1040 for 1988 stated that Mrs. Marzullo was self-employed. Petitioners understated the gross receipts of MPM on their Federal income tax returns as follows: Year Actual Receipts Reported Receipts 1987 $71,750 $14,900 1988 44,722 19,682 Respondent increased the expenses attributable to MPM's operationsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011