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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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