Franklin D. and Sandra M. Terrell - Page 3




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               Petitioners filed their 1991 income tax return on January 8,           
          1993, and their 1992 and 1993 income tax returns on May 11, 1994.           
          Petitioners did not file extensions to file their income tax                
          returns for any of the years in issue.                                      
               Petitioners failed to report interest income earned from               
          their bank accounts in the amounts of $1,201, $932, and $433, for           
          their 1991, 1992, and 1993 taxable years, respectively.                     
               Petitioners had unreported rental income in the amounts of             
          $14,842, $7,472, and $14,405 for their 1991, 1992, and 1993                 
          taxable years, respectively.  In 1993, petitioners received a               
          portion of the unreported rental income from the rental of their            
          residence at 5260 Maymont Drive, Los Angeles, California.                   
               Petitioners had unreported Schedule C income of $12,780,               
          $51,858, and $58,608, for their 1991, 1992, and 1993 taxable                
          years.  Respondent estimated and allowed Schedule C expenses in             
          the amounts of $14,218, $38,526, and $39,524, for petitioners'              
          1991, 1992, and 1993 taxable years, respectively; respondent's              
          estimate, which was based on a percentage of petitioners' gross             
          receipts, was required due to petitioners' failure to keep                  
          adequate records to substantiate their claimed Schedule C                   
          expenses.                                                                   










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