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for 1993, 1994, and 1995. In Schedule C of their return for each
of the years 1991 and 1992, petitioners indicated that their
principal business or profession was consulting service, continu-
ing education, and publishing. They further indicated in each
such Schedule that the name of their business was IAMCM and that
the employer identification number (EIN) for that business was 43-
1577193.
Petitioners included a Schedule E, Supplemental Income and
Loss (Schedule E), with each of their 1993, 1994, and 1995 re-
turns. In part II, Income or Loss From Partnerships and S Corpo-
rations, of each of those Schedules, petitioners claimed, inter
alia, that they had a loss from an S corporation. They identified
that corporation as IAMCM in part II of Schedules E of their 1993
and 1994 returns and as IAMCM/PRINCIPIA in part II of Schedule E
of their 1995 return. Petitioners further indicated in those
Schedules E that the EIN of that claimed S corporation was 43-
1577193, the same EIN of the business called IAMCM that they
identified in Schedules C of their 1991 and 1992 returns.
During the examination in late 1996 by the Internal Revenue
Service (Service) of petitioners’ years at issue, the Service’s
examining agent (agent) requested copies of Forms 1120S for IAMCM.
The agent renewed his request in January 1997.
In February and March 1997, petitioners prepared and mailed
to the agent a Form 1120S, U.S. Income Tax Return for an S Corpo-
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