- 4 - 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 inPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011