Julie Pusateri - Page 3

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               The paralegal business for Schedule C-1 was operated out of            
          an office owned by petitioner's husband.  The office was located            
          in her husband's house.  Petitioner did not pay rent to her                 
          husband or to a landlord for the use of the office.  The office             
          had a fax machine, a computer, shelves for supplies, a telephone,           
          a printer, and similar items.  Petitioner paid for her own                  
          supplies.  The paralegal business for Schedule C-2 was operated             
          out of the Legal Assistance Center.                                         
               In 1991, petitioner maintained a checking account with Union           
          Bank.  She also maintained an account with Wells Fargo Bank under           
          the name "Legal Assistance Center".  Petitioner testified that              
          all earnings from her Schedule C-1 paralegal business were                  
          deposited into the Union Bank account, and that all earnings from           
          her Schedule C-2 paralegal business were deposited into the Wells           
          Fargo bank account.  The parties stipulated that the total gross            
          receipts from petitioner's Schedule C-1 paralegal business in the           
          Union Bank checking account were $29,056 in 1991.  (The $258                
          difference between this amount and the $29,314 reported on the              
          Schedule C-1 was due to a mistake.)                                         
               On her Schedule E, Supplemental Income and Loss, petitioner            
          reported "rent income" of $6,720 from "residential" property in             
          San Diego, and "rent income" of $1,600 from "equipment and                  
          furniture", for a total of $8,320.  On the Schedule E, petitioner           
          also deducted expenses of $200 for cleaning, $100 for insurance,            





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