James E. Zurcher - Page 4

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          business license in his name.  Petitioner did not have a business           
          name, and he did not have a business telephone.  Petitioner did             
          not belong to any trade association, and he did not have any                
          employees.  Petitioner did not advertise the Property for sale;             
          all advertising was done by a real estate agent with whom                   
          petitioner listed the Property for sale.                                    
               Petitioner filed a 1992 Form 1040, U.S. Individual Income              
          Tax Return, using the filing status of "Single".  The return was            
          prepared by petitioner's long-time tax preparer, a certified                
          public accountant (C.P.A.), and it listed petitioner's occupation           
          as "investments".  Petitioner's 1992 gross income was $186,003,             
          exclusive of a $3,000 capital loss and a $71,504 loss that he               
          reported on the sale of the Property.  Most of petitioner's gross           
          income was from interest, dividends, and petitioner's involvement           
          in numerous partnerships.                                                   
               Petitioner reported the $71,504 loss on his 1992 Schedule C,           
          Profit or Loss From Business (Sole Proprietorship), as an                   
          ordinary loss: $71,304 of this amount was due to the loss on the            
          sale of the Property and $200 was attributable to "Legal and                
          professional fees".  The Schedule C stated that petitioner was a            
          "developer", that he had operated his business for 5 months                 
          during 1992, and that his business was not in operation at the              
          end of 1992.  Petitioner and his C.P.A. discussed petitioner's              
          financial data before the C.P.A. prepared petitioner's return,              
          and they discussed the facts behind petitioner's involvement in             




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