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Apparently prior to 1991, petitioner moved to Delhi, New
York, approximately 250 miles from Central Square. During 1991,
petitioner, his wife, and his daughter resided in a rental house
in Delhi. Sometime in 1991, petitioner's wife obtained
employment in Delhi. Petitioner stayed in Delhi 5 days a week
and worked in his businesses. He taught in Oswego, New York, 2
days a week.
On Schedules C, petitioner reported total losses of
$18,710.62 from the following businesses: Cobra Productions, a
video tape production/distribution business; Paradise Therapy
(Paradise), a mental health therapy business; Dr. Bernard Boozer
(Boozer), a management consultant business; and Charley's, a
restaurant. On his Schedule C for Paradise, petitioner, inter
alia, claimed a deduction for bad debts from sales or services in
the amount of $2,625.90. On his Schedule C for Boozer,
petitioner, inter alia, claimed a deduction for rent or lease of
other business property in the amount of $4,800.
On or about April 15, 1992, petitioner requested, and was
granted, an extension of time to file his 1991 return by August
15, 1992. On May 24, 1993, respondent mailed to petitioner a
Request For Your Tax Return for tax period ending December 31,
1991, because respondent's records showed that petitioner had not
filed a tax return, Form 1040, U.S. Individual Income Tax Return
for 1991. On April 18, 1994, petitioner filed his 1991 return.
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