Thomas and Linda O'Connell - Page 6




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          Terrors entered many tournaments during the years in issue.  The            
          fishing tournaments were funded by moneys advanced to Billfish by           
          petitioner.  Billfish made interest-free loans to Texas Terrors,            
          which were the sole source of funds for Texas Terrors.                      
          Petitioner did not charge Billfish interest on the loans.  If               
          Texas Terrors won prizes in fishing tournaments, the money was              
          given to the team members.  The prize money was not reported as             
          taxable income to Texas Terrors.  Texas Terrors reported the                
          following gross income, expenses, and income or loss on its                 
          Federal income tax returns for the years indicated:                         
               Year     Gross Income     Expenses     Income(Loss)                    
          1984       $25,568        $154,296      ($127,728)                          
          1985        53,565         221,061       (167,496)                          
          1986        49,195          81,710        (32,515)                          
          1987          -             40,681        (40,681)                          
          1988          -             59,432        (59,432)                          
               Billfish did not file timely Federal income tax returns for            
          1989 or 1990, and Texas Terrors did not file a timely return for            
          1989.  Billfish did not maintain records sufficient to                      
          substantiate the travel expenses, meals and entertainment                   
          expenses, and other expenses of operating Renegade during the               
          years in issue.                                                             
               Losses incurred by Billfish and by Texas Terrors were                  
          deducted against other income of petitioners on their Federal               
          income tax returns for the years in issue.                                  








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