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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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