- 29 - of $40,207 and interest income of $3,784.12 For 1991, petitioner reported wages of $57,344 and interest income of $4,139.13 During the years at issue, petitioner was employed by SOI and earned wages of $54,118 and $38,029 for 1992 and 1993, respectively. Additionally, for 1992, petitioner reported interest income of $2,757, a State income tax refund of $245, a $3,000 capital loss, and a $1,940 loss from the operation of rental real estate. For 1993, petitioner reported interest income of $2,225, a State income tax refund of $729, a $3,000 capital loss, and a loss of $1,817 from the operation of rental real estate. For each of the years of operation, the amounts of income derived by petitioner outside of BRVC are not so high as to indicate that petitioner's primary objective in operating BRVC was to generate tax savings, particularly in light of the other losses reported on petitioner's returns for various years. On the contrary, these levels of other income and losses indicate that petitioner lacked the luxury of a large amount of disposable income that would enable her to fritter away tens of thousands of dollars each year on a volleyball hobby. The tax incentive for 12 In addition to the BRVC loss for 1990, petitioner reported a $3,000 capital loss, a $3,057 loss from the operation of rental real estate, and a net operating loss carryover of $36,517. 13 Additionally, petitioner reported a $3,000 capital loss, a $5,512 loss from the operation of rental real estate, and a $24,388 net operating loss carryover.Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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