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Ms. Feltrinelli
Adjustments to income &
expenses 1989 1990
Car and truck expenses $1,684 $1,782
Franchise fee income 5,000 5,000
Sec. 482 allocation 228 19,010
Self-employment tax
deduction (1,822)
Total $6,912 $23,970
Mr. and Mrs. Owens reported that their cost of goods sold
and business expenses were $284,288 in 1989 and $302,923 in 1990.
Respondent allowed $209,031 for 1989 and $252,353 for 1990 for
those items.
Ms. Feltrinelli reported that she had gross receipts of
$704,593 in 1989 and $781,212 in 1990. Respondent determined
that her gross receipts were $161,591 in 1989 and $198,759 in
1990.
Ms. Feltrinelli claimed that her total cost of goods sold
and business expenses were $686,058 in 1989 and $763,718 in 1990.
Respondent allowed $142,828 in 1989 and $162,255 in 1990.
E. Partial Trial
1. Pretrial Activities
These cases were calendared for trial at the sessions in
Atlanta, Georgia, beginning on September 26, 1994, for Mr. and
Mrs. Owens and on October 31, 1994, for Ms. Feltrinelli. The
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