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taxable year with the Director, Ogden Service Center in
Ogden, Utah.
(e) The petitioner signed the joint 1982 federal
income tax return referred to in subparagraph 6.(d) above on
her own behalf and on behalf of Wayne E. Palmer as "his
attorney in fact."
(f) The petitioner's 1982 joint federal income tax
return reflected total income of $0 and total tax liability
in the amount of $0. Said return made no mention of any
business income or expenses or of any other income received
by either the petitioner and/or Wayne E. Palmer during that
taxable year.
(g) On her joint 1982 federal income tax return,
the petitioner listed her occupation as "disabled."
(h) On or about May 17, 1984, the petitioner filed
a joint federal income tax return (Form 1040) with Wayne E.
Palmer for the 1983 taxable year with the Director, Ogden
Service Center in Ogden, Utah. The sole income listed on
said return is a loss in the amount of $10,524 which is
reflected on a Schedule C (Profit (or Loss) From Business or
Profession) from a business known as "Mill Direct Carpets."
That Schedule C lists the petitioner as the sole proprietor
of that business.
(i) On the Schedule C referred to in subparagraph
6.(h) above, the petitioner listed gross receipts or sales
in the amount of $343,607. After subtracting the claimed
cost of goods sold, returns and allowances, the petitioner
listed gross income from Mill Direct Carpets of $103,504,
total deductions in the amount of $114,028, and a net loss
from the business of $10,524.
(j) The petitioner listed total income tax
liability of $0 on her 1983 joint federal income tax return.
(k) On or about April 15, 1985, the petitioner
filed a joint federal income tax return (Form 1040) with
Wayne E. Palmer for the 1984 taxable year with the
Director, Ogden Service Center in Ogden, Utah. The sole
income listed on said return is on an attached Schedule C
which reflects a net loss in the amount of $4,519 from the
operation of Mill Direct Carpets by the petitioner.
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