Paul Mifsud and Maria G. Mifsud - Page 13




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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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