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31, 1990. Total liabilities included loans of $45,969.82 from
officers and shareholders.
Business cards for the police dog training business and
correspondence such as vendor and utility bills and marketing
brochures did not state that the business was incorporated. Some
of those documents were prepared in the name of Southern Police
Dog Academy.
Petitioners applied for a Federal identification number for
Rosewood Kennels, Inc., on March 12, 1991.
2. S Corporation Election
On April 22, 1991, Rosewood Kennels, Inc., received a notice
from respondent accepting its S corporation election.
3. Petitioners' Income Tax Returns
On June 25, 1991, petitioners and Oddo signed petitioners'
income tax return for 1990. Petitioners reported the income and
expenses from the police dog training business on a Schedule C.
Petitioners reported that the business lost $159,426 in 1990.
Petitioners deducted the mortgage interest they paid on the
United Bank loan on that Schedule C. They said the business was
"Rosewood Kennels, Inc. d/b/a Southern Police Dog Academy".
Petitioners filed their 1990 return on June 28, 1991.
Oddo prepared an undated corporate return with zeros
throughout for Rosewood Kennels, Inc., Southern Police Dog
Academy, for 1990.
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