Joao Montoro and Neuza Paula - Page 11

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          $3,752 from her import sales business in 1990, as petitioners               
          reported on their amended return for 1990.                                  
               3.   International                                                     
               Petitioners reported that International had gross receipts             
          of $23,574 in 1990 and $147,426 in 1991, cost of goods sold and             
          expenses of $39,550 in 1990 and $162,917 in 1991, and losses of             
          $15,976 in 1990 and $15,491 in 1991.                                        
               Petitioner-husband deducted Schedule C expenses for                    
          International of $22,963 in 1990 and $30,234 in 1991.  The                  
          parties agree that petitioners' taxable income should be                    
          decreased by $1,119 in 1990 and increased by $4,670 in 1991                 
          because of changes to International's Schedule C expenses for               
          those years.                                                                
               4.   Net Operating Loss Carrybacks                                     
               Petitioners reported net operating losses of $15,976 on                
          their original return ($14,448 on the amended return) for 1990              
          and $15,491 on their return for 1991.  Petitioners elected to               
          carry the net operating losses back to 1987 and 1988 by filing              
          Forms 1045.  Petitioners' net operating losses equaled the                  
          Schedule C losses from International in 1990 and 1991.                      
          H.   Respondent's Examination                                               
               Revenue Agent Margaret Davis (Davis) began to examine                  
          petitioners' returns for 1990 and 1991 late in 1992.  Davis asked           
          petitioners for the books and records of International, including           






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