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Petitioner and his wife filed a joint Federal income tax
return for 1988. The return was received by the Internal Revenue
Service on May 22, 1992, although the signature lines on the
return bear signature dates of April 3, 1989.2
Petitioner filed a Schedule C, Profit or Loss From Business,
with his 1988 Federal income tax return in connection with his
book-selling activity. That schedule reflected the following
items of income and expenses:
Income:
Gross receipts or sales $16,250
Less cost of goods sold 9,750
Gross income $ 6,500
Expenses:
Advertising $1,220
Bank service charges 145
Car and truck expenses 3,651
Office expense 755
Rent on business property 1,200
Travel 1,760
Meals and entertainment (net) 852
Utilities and telephone 4,230
Wages 550
Exhibit spaces 4,460
Total 18,223
Net loss $12,323*
* The expenses shown total $18,823 rather than $18,223
shown on petitioner's return. The $12,323 net loss is the
correct figure.
2
The notice of deficiency is addressed jointly to petitioner
and his wife Maureen. His wife did not petition the Court, nor
did she appear at trial. Petitioner referred to her at trial as
his "ex-wife" and testified she was living in Florida. Their
current marital status is not indicated in the record.
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