Kenneth Lee and Margaret Ihlenfeldt - Page 4




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          services during all of the relevant years in addition to the                
          activities which he performed through Delta and the corporations.           
               Petitioner did not timely file a Federal income tax return             
          for any of the subject years.  He filed 1989 and 1990 Federal               
          income tax returns using the filing status of married filing                
          joint return.  He filed a 1991 and a 1992 Federal income tax                
          return using the filing status of married filing separate                   
          return.3  He never filed a 1993 Federal income tax return before            
          the notice of deficiency for that year was issued.                          
               Petitioner’s 1989 through 1992 returns reported the                    
          following taxable income:                                                   
          1989      1990     1991      1992                                           
          Wages                  $115      $469     $405      $242                    
          Interest income       1,808       -0-       50        70                    
          Taxable tax refund      -0-       160      -0-       -0-                    
          Business loss        77,997   107,052   34,181    57,432                    
          Gambling winnings     9,469       -0-      -0-       -0-                    
          Taxable income      (66,605) (106,423) (33,726)  (57,120)                   
          His accompanying Schedules C, Profit or Loss From Business (Sole            
          Proprietorship), reported that the business losses were                     
          attributed to the following items of income and expense:                    







               3 None of the amounts set forth in the 1992 return are                 
          reflected in the notice of deficiency for that year because                 
          petitioner filed that return right before respondent issued to              
          him the notice of deficiency.                                               




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