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prepare their 1995 returns, bank statements, and similar
documents. Joseph and Frances Shirley and Curtis Shirley
appeared for the meeting but did not produce the requested
documents. They refused to answer respondent’s agent’s
questions, responding to her questions with questions and a
questionnaire of their own. They refused to give respondent’s
agent a copy of that questionnaire.
The J. Shirleys
The J. Shirleys made a joint return of income for 1995 (the
J. Shirleys 1995 return). In that return, they reported $4 of
interest and $13,749 of “NonPassive Income”, both from Caralan
Trust, and claimed a depreciation deduction, in the amount of
$19,896, on account of property owned by Caralan Trust; they also
claimed a standard deduction of $6,550 and a deduction of $5,000
for personal exemptions. They reported no other items of income,
loss, or deduction. They reported zero taxable income. Joseph
Shirley reported his occupation as “consultant”.
For an indeterminate number of years prior to 1995, the
J. Shirleys reported on their Federal income tax returns that one
or both was engaged in the computer consulting business.
During those years, they paid self-employment taxes on the net
profits of that business.
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Last modified: May 25, 2011