Xavier J.R. and Sulochana D. Avula - Page 3




                                          -3-                                         
          Sulochana D. Avula (Ms. Avula) was employed as a technician at a            
          pharmacy.                                                                   
               In October 1989, the State of Missouri authorized Interna-             
          tional Academy of Mathematical and Computer Modelling, Inc., to             
          conduct business as a not-for-profit corporation.  Petitioners own          
          100 percent of the stock of that corporation.  Effective January            
          1, 1991, the State of Missouri canceled the corporate license of            
          the International Academy of Mathematical and Computer Modelling,           
          Inc., because the corporation failed to file a correct annual               
          report with the secretary of state of Missouri.  In May 1999,               
          petitioners contacted the State of Missouri about the Interna-              
          tional Academy of Mathematical and Computer Modelling, Inc.  On             
          July 15, 1999, the International Academy of Mathematical and                
          Computer Modelling, Inc., became an active not-for-profit corpora-          
          tion.                                                                       
               Petitioners filed a joint Federal tax return (return), Form            
          1040, for each of the years at issue on the date indicated:                 

                        Form 1040            Filing Date                              
                           1991             April 14, 1995                            
                           1992             April 17, 1996                            
                           1993            November 4, 1996                           
                           1994           November 22, 1996                           
                           1995            December 3, 1996                           
               Petitioners included a Schedule C, Profit or Loss From                 
          Business (Schedule C), with each of their 1991 and 1992 returns.            
          Petitioners did not include a Schedule C with any of their returns          






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