Ilya G. and Sophia K. Margolis - Page 3




                                        - 3 -                                         

               Petitioners are a married couple.  Throughout the year in              
          issue, petitioner-husband (Mr. Margolis) was self-employed as a             
          photographer and petitioner-wife (Mrs. Margolis) was self-                  
          employed as a textile designer.                                             
               In June 1992 Mrs. Margolis became associated with Leo Art              
          Studios, Inc. (Leo Art), located in Manhattan, New York.  She               
          received $14,180 from Leo Art in 1992 from the sale of her                  
          textile designs.  Leo Art paid Mrs. Margolis by checks ranging in           
          amount from $350 to $800.  Mrs. Margolis deposited the first                
          three checks she received from Leo Art, each in the amount of               
          $500, to petitioners' account at National Westminster Bank.  Mrs.           
          Margolis cashed the remaining checks.                                       
               Petitioners resided in a three bedroom apartment in Kew                
          Gardens, New York.  One of the bedrooms was converted into a work           
          area utilized exclusively by Mrs. Margolis throughout 1992 as a             
          home office.  Mrs. Margolis used the home office mainly to                  
          prepare her textile designs.                                                
               On their 1992 Federal income tax return, petitioners claimed           
          a net Schedule C loss for Mr. Margolis' photography business in             
          the amount of $11,121.  Petitioners reported $13,621 in                     
          unemployment compensation income received by Mrs. Margolis.                 
          Petitioners did not report any income or claim any loss for Mrs.            
          Margolis' textile design business.                                          
               In the notice of deficiency, respondent determined that                
          petitioners failed to report $14,755 in self-employment income              
          earned by Mrs. Margolis as a textile designer.                              

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  Next

Last modified: May 25, 2011