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not much better financially. For these years, petitioner
reported the following losses:
1990 $18,521
1991 20,957
1992 24,926
1995 12,217
1996 15,549
1997 34,425
At trial, petitioner testified she believed she would realize a
net profit of $7,500 for 1998; however, she had no books and
records to support that testimony, and she had not yet filed her
income tax return for 1998. Petitioner acknowledged she did not
maintain accounting records to reflect income, expenses, and
profits or losses, although she maintained a file folder in which
she kept her receipts. It appears that petitioner calculated her
profits or losses for income tax purposes only at or about the
time such returns were due.
After graduating from high school in 1983, petitioner
attended Southwest Texas State University at San Marcos, Texas,
and earned a bachelor's degree in business with an emphasis in
marketing. After receiving her degree, petitioner obtained full-
time employment at or near San Antonio, Texas, and drove to her
employment each day from her parents' home, a distance of 8 to 10
miles. Although the nature of petitioner's employment and her
employer's business were not established at trial, neither the
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