Randall and Lynn Bishop - Page 3




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          as we proceed.  Petitioners bear the burden of proof.  See                  
          Rule 142(a).                                                                
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the year at issue, and              
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
                                     Background                                       
               Hereinafter, petitioners Randall and Lynn Bishop will be               
          referred to as the Bishops or, individually, as Randall and Lynn.           
               At the time of the petition, the Bishops resided in Bonita             
          Springs, Florida.                                                           
               During 1994, the Bishops resided in Burlingame, California.            
          Until July 8, 1994, Randall was employed as a financial planner             
          by Wells Fargo Bank in San Francisco, California, and, during               
          1994, Lynn was employed as a flight attendant.  During 1994,                
          Randall also carried on a financial planning business (the                  
          financial planning business) separate from his employment by                
          Wells Fargo Bank.  Customers of the financial planning business             
          came from referrals to Randall or from seminars conducted by                
          Randall.   The Bishops made a joint return of income for 1994,              
          filing a  U.S. Individual Income Tax Return, Form 1040 (the Form            
          1040), which included, among other schedules, a Schedule A,                 
          Itemized Deductions (the Schedule A), and a Schedule C, Profit or           
          Loss From Business (Sole Proprietorship) (the Schedule C).                  






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