- 3 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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