Zinovy Brodsky - Page 95




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          “CONSIGNMENT SALES - CD’s” (consignment sales business).11  Part            
          I, Income, of the 1993 Schedule C relating to the wholesale                 
          business reported “Gross receipts or sales” of $158,022, “Cost of           
          goods sold” of $137,990, and “Gross income” of $20,032.  The 1993           
          Schedule C for the wholesale business showed “Total expenses                
          before expenses for business use of home” of $23,025, “Expenses             
          for business use of your home” of $4,867, and “Net profit or                
          (loss)” of ($7,860).  Part I, Income, of the 1993 Schedule C                
          relating to the consignment sales business reported no “Gross               
          income”, “Total expenses before expenses for business use of                
          home” of $1,500, and “Net profit or (loss)” of ($1,500).                    
               The 1993 joint return also included Schedule D.  Part II of            
          the 1993 Schedule D, Long-Term Capital Gains and Losses, reported           
          “Gain from Form 4797" of $11,315, “Long-term capital loss carry-            
          over from 1992 Schedule D” of $27,000, and “Net long-term capital           
          gain or (loss)” of ($15,685).                                               
               The 1993 joint return also included Form 4797, Sales of                
          Business Property (Form 4797), that was referenced in Part II of            
          the 1993 Schedule D.  In Part III of that form, Gain From Dispo-            
          sition of Property Under Sections 1245, 1250, 1252, 1254, and               
          1255, petitioner and Ms. Brodsky reported that on January 1,                
          1993, they sold for $48,000 an interest in the Sanchez Street               



               11The respective Schedules C for those two businesses did              
          not list the names under which petitioner operated them.                    





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