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Corporate Owner--
Restaurant Year Mr. Mifsud Ms. Mifsud Total
Nichole & Eric, 1992 $12,100 $12,100 $24,200
Inc.--Breakfast
Club of 7 Hills 1993 11,450 11,450 22,900
1994 8,400 8,400 16,800
Paul & Joe, Inc.-- 1992 11,150 14,600 25,750
Spring Hill
restaurant 1993 8,050 8,050 16,100
1994 8,575 8,500 17,075
Crystal & Ryan, 1992 12,100 12,100 24,200
Inc.--The
Breakfast Club 1993 11,400 11,400 22,800
1994 8,500 8,500 17,000
Total by Year 1992 35,350 38,800 74,150
1993 30,900 30,900 61,800
1994 25,475 25,400 50,875
In their return for each of the years at issue, petitioners
reported a capital loss of $3,000. They also reported subchapter
S losses of $20,002 in their 1992 return, $13,499 in their 1993
return, and $9,392 in their 1994 return. The amounts of total
income reported by petitioners in their returns for 1992, 1993,
and 1994 were $80,130, $74,699, and $62,658, respectively.
Petitioners reported the following amounts of interest
income in Schedule B, Interest and Dividend Income, of their
return for each year indicated:
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