Kenneth D. Shepherd and Martha A. Gregory - Page 3

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          least one other person.  Petitioner husband's claimed training is           
          in the area of chemical engineering and electronics.                        
               Prior to their marriage, petitioner husband was involved in            
          developing a golf club cleaning machine made by Ree-Born                    
          Industries, Inc.  Specifically, petitioner husband worked on                
          formulating the chemical solution used to clean golf clubs.  He             
          also negotiated with Ree-Born Industries, Inc. for the rights to            
          market the machine to potential purchasers, such as country                 
          clubs.                                                                      
               Petitioner husband experienced some financial difficulties             
          in his efforts to market the golf club cleaning machine.  On July           
          1, 1989, he signed a promissory note, in the amount of $6,000,              
          payable to his current wife Martha Gregory. The promissory note             
          states that the entire debt was to be paid in a lump sum on                 
          January 1, 1990, together with interest computed at a variable              
          rate.  No payments were made on the moneys, if any, advanced to             
          petitioner husband, nor did petitioner wife ever request any such           
          payments.                                                                   
               Petitioners were married on March 15, 1990, and filed joint            
          Federal income tax returns for 1991 and 1992.  On those returns,            
          petitioners claimed Schedule C deductions for alleged losses                
          resulting from their activity in "Information Brokering Products            
          & Services" operated under the name of MGO Information Services.            
          Petitioners also claimed a capital loss deduction in the amount             
          of $3,000 on their 1991 return.  The deduction was claimed as a             




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