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the name of "Jacobs Creative Group". Those deductions claimed by
petitioners, in the amount of $40,612, exceeded the gross income
of $21,876 reported on Schedule C as the income of Jacobs
Creative Group, which respondent did not dispute, and reduced the
taxable income from the salary of petitioner Jennie Jacobs
(Ms. Jacobs) reported on their joint return.
After making some findings of fact of general application,
reciting the procedural history of the case, and providing an
introductory exposition of applicable law, we shall, for
convenience, combine our findings, discussion and holding under a
separate heading for each type of expense in issue.
Petitioners timely filed an electronic joint return for
1992. At the time petitioners filed their petition, they resided
in Reno, Nevada. Petitioners were divorced in 1996.
The case was continued from the Court's May 20, 1996, and
May 4, 1997, Reno, Nevada, general trial sessions on petitioners'
motions on the ground of petitioner's asserted inability to
prepare for trial by reason of “Chronic Fatigue Immune
Dysfunction Syndrome (CFIDS)” and a spinal injury.
In due course, the case was placed on the Court's May 4,
1998, Reno, Nevada, general trial session. During the week
immediately preceding the session, in response to petitioner's
telephone message that he wished to request another continuance,
the Court informed petitioner and respondent that no more
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