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showed $8,558 as the C. Shirley’s share of depreciation computed
by Congo Trust.
The C. Shirleys
The C. Shirleys made a joint return of income for 1995 (the
C. Shirleys 1995 return). In that return, they reported no items
of income and claimed a deduction in the amount of $10,463 on
account of “Unreimbursed Expenses” related to Congo Trust; they
also claimed a standard deduction of $6,550 and personal
exemptions of $7,500. In calculating taxable income, they
reported no other items of income, loss, or deduction. A
schedule attached to the C. Shirleys 1995 return shows
depreciation of $8,558 from Congo Trust, but no deduction of such
depreciation enters into their calculation of taxable income.
They reported zero taxable income. Curtis Shirley reported his
occupation as “manager”.
Curtis Shirley’s occupations are computer consultant and
headhunter. During 1995, he was self-employed as a computer
consultant, performing those services personally, for
compensation. During 1995, he did some work under contracts with
C E Shirley Trust, as a subcontractor.
In 1995, Curtis Shirley personally performed computer
consulting services for Ventana Consulting Solutions (Ventana).
Two bank checks, in payment for those services, in the amounts of
$1,495 and $975 (total, $2,470), dated December 21 and 28, 1995,
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