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stipulated to be $24,240, $8,623, and $16,347 (before deduction
of any net operating loss carryovers).
Petitioner filed her Federal income tax returns for 1991 and
1992 on October 1, 1993. These returns were not timely filed.
Petitioner timely filed her Federal income tax return for 1993.
On her Federal income tax returns for 1991, 1992, and 1993,
petitioner reported Schedule E losses in the following amounts
from Special Occasions, Klyce Day Care, and Special O:
Partnership/S Corp 1991 1992 1993
Special Occasions ($ 1,967) ($ 2,816) ($ 2,689)
Klyce Day Care ( 4,898) ( 4,898) ( 3,200)
Special O ( 6,875) ( 9,895) ( 13,777)
Total losses ($13,740) ($17,609) ($19,666)
Petitioner reported no income or loss from Sweets 'N' Things for
1991, 1992, or 1993.
In August 1996, petitioner filed Forms 1040X, Amended U.S.
Individual Income Tax Return (amended returns), for her 1991,
1992, and 1993 tax years. On these amended returns petitioner
claimed Schedule C losses from Sweets 'N' Things of $3,910,
$5,254, and $569, respectively, for 1991, 1992, and 1993.
Prior to issuing the notice of deficiency for 1991, 1992,
and 1993, respondent issued separate Revenue Agent's Reports
(RAR) to Special Occasions and Special O in which respondent made
adjustments in income and deductions. Respondent used the bank
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