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Rule references are to the Tax Court Rules of Practice and
Procedure. All dollar amounts are rounded.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The
stipulation of facts and the attached exhibits are incorporated
herein by this reference.
Background
Petitioners, husband and wife, resided in Baltimore, Maryland,
at the time they filed their petition. They married in 1968 and
have three children. For over 25 years, petitioner operated
several small businesses in the Baltimore area, including a
grocery/convenience store. During the period in issue, Mrs. Taylor
remained at home and took care of the children.
Grocery/Convenience Store Business
In 1969 or 1970, petitioner began operating a "mom and pop"
grocery/convenience store under the name M&E, Inc. (Despite its
name, M&E, Inc., was a sole proprietorship of petitioner.) Many of
petitioner's business records were in disarray. Bills for
business expenses were kept in boxes, and daily gross receipts were
recorded on a calendar.
Mrs. Taylor began working in the store sometime in 1990 when
petitioner's criminal problems resulting from his check-kiting
scheme (discussed infra) overwhelmed him. Following petitioner's
incarceration in January 1991, Mrs. Taylor ran the store with one
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