Michael E. and Johanna S. Davis - Page 5




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          income of $1,788, taxable dividend income of $182, a State income           
          tax refund of $605, and taxable pension income of $2,100.                   
          Petitioners deducted a net loss from Jojoba Hawaii of $12,971,              
          which they reported on Schedule E, Supplemental Income Schedule,            
          as a partnership loss.  Thus, petitioners reported total income             
          of $93,795 and a tax liability of $13,959.                                  
               On their joint 1983 Federal income tax return, petitioners,            
          in the same fashion, reported wages of $45,989 from petitioner              
          husband's employment and $29,145 from petitioner wife's                     
          employment.  Petitioners also reported interest income of $2,224,           
          a State income tax refund of $1,803, and a Schedule E net loss              
          from Jojoba Hawaii of $1,017.  Thus, petitioners reported total             
          income of $78,144 and a tax liability of $7,515.                            
               On their joint 1984 Federal income tax return, petitioners             
          likewise reported wages of $52,086 from petitioner husband's                
          employment, $30,145 from petitioner wife's employment, interest             
          income of $879, a loss on Schedule C, Profit or (Loss) From                 
          Business or Profession, of $15,767 from a commercial fishing                
          activity, a Schedule F, Farm Income and Expenses, net farm loss             
          of $1,650, and a Schedule E loss from Jojoba Hawaii of $1,205.              
          Thus, petitioners reported total income of $64,488 and a tax                
          liability of $3,757.                                                        
               On their joint 1985 Federal income tax return, petitioners             
          similarly reported wages of $57,059 from petitioner husband's               





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