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Petitioners received income from sources other than the jade
activity in 1996. In 1996, petitioner was employed by Laurel
Travel, and petitioner Joan M. Marvin was employed by Marriott
International. From these employments in 1996, petitioners
received wage income in the amount of $28,669.39.
For the years 1996 through 1998, petitioners' jade activity
consistently generated minimal income and large deductions. On
the Schedule C attached to their 1996 Federal income tax return,
petitioners reported no income and claimed deductions in the
amount of $18,440. For the year 1997, petitioners reported $50
of gross receipts and $18,528.85 of deductions. For the year
1998, petitioners claim that Glacial Jadeite had gross receipts
of $250 and expenses in the approximate amount of $18,000.
Moreover, petitioners’ claims that Glacial Jadeite is involved in
profitable projects is unavailing. Petitioners have failed to
provide reliable documents that substantiate their assertions and
we refuse to rely upon petitioner's self-serving testimony. See
Niedringhaus v. Commissioner, 99 T.C. 202, 219-220 (1992);
Tokarski v. Commissioner, 87 T.C. 74, 77 (1986). Furthermore,
petitioners have also failed to explain how and to what extent
they would financially benefit from these supposed projects.
Lastly, petitioners received personal pleasure from the jade
activity. Petitioner's activities provided a source of
recreation that satisfied petitioner's personal interest in jade.
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