George R. and Donelle C. Hawthorne - Page 5




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          Dividends in Stock Under Dividend Reinvestment Programs                      
               Prior to the years at issue, petitioners enrolled in the                
          respective dividend reinvestment programs of various companies in            
          which they owned shares of stock.  Pursuant to those programs,               
          petitioners elected to receive dividends on those shares in                  
          stock, rather than in cash.  Pursuant to those elections, peti-              
          tioners received dividends in the amounts of $8,324.76,                      
          $8,123.74, and $8,759.81 during 1992, 1993, and 1994, respec-                
          tively, that were paid in stock.  They reported those respective             
          amounts as dividend income in their returns for those years.                 
          Schedule C Income and Expenses Claimed by Petitioners                        
               Schedule C Income Claimed by Petitioners                                
               Around 1980, Mr. Hawthorne sold a motel and reported no gain            
          from that sale.  Pursuant to the terms of the real estate con-               
          tract relating to that sale, Mr. Hawthorne received $1,957.68 in             
          interest income during 1992.  Petitioners reported that income in            
          Schedule C of their 1992 return.  Petitioners did not report any             
          other income in that Schedule C or in the Schedules C of their               
          1993 and 1994 returns.                                                       
               Schedule C Expenses Claimed by Petitioners                              
               Mr. Hawthorne owned one or more real properties (properties)            
          in different locations throughout the United States, including               
          Cape Coral, Florida; Pagosa Springs, Colorado; and Elephant                  
          Butte, Santa Fe, and Albuquerque, New Mexico.  Mr. Hawthorne and             
          petitioner Donelle C. Hawthorne (Ms. Hawthorne) owned one prop-              
          erty in Cape Coral, Florida, as community property.  At least                


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