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Berkeley restaurant in June 1989. In 1990 and 1991, Toraya
operated only the Post Street restaurant.
During 1988 through 1991, Akiko worked at the Post Street
restaurant, usually as a hostess. When the restaurant was busy,
however, she would write orders. During 1988 through 1991,
Yoshinori worked mostly at the Post Street restaurant, as a chef,
although he sometimes worked also at the Berkeley restaurant. In
1990 and 1991, Akiko or Motomi handled the cash at the Post
Street restaurant.
During the years in issue, the Takaos owned a two-thirds
interest in the Toraya Apartments.
The Takaos' tax returns for 1989 through 1991 indicate
Yoshinori's occupation as "Retired". The Takaos' tax returns for
1990 and 1991 indicate Akiko's occupation as "Retired".
The Takaos reported the following items of taxable income
(or loss) on their tax returns for the years 1988 through 1991:
Amount
Item 1988 1989 1990 1991
Wages $7,675 $6,440 $5,000 $4,800
Interest 45,299 50,643 46,553 40,999
Dividends -- -- -- --
Refunds 2,388 -- 528 264
Sch. C income (159) 699 857 (14,150)
Capital gain
(or loss) (3,000) -- (3,000) (3,000)
Other gains
(or losses) -- -- -- (12,500)
IRA distributions 3,371
Sch. E income 15,230 174 (7,116) 5,317
Social security -- -- 87 --
Total 67,433 57,956 42,909 25,101
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