Tommy Owens, Jr. and Dawn R. Owens - Page 7




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               During 1993, 1994, and 1995, petitioners paid cost of goods            
          sold for Mr. Owens’ painting business totaling $24,121, $64,514,            
          and $91,607, respectively.                                                  
               During 1993, 1994, and 1995, petitioners paid business                 
          expenses for the painting business, excluding amounts paid for              
          Schedule C car and truck expenses, totaling $29,710, $34,023, and           
          $71,453, respectively.                                                      
               During 1993, 1994, and 1995, petitioners incurred $2,466.62,           
          $7,355.11, and $9,718.11, respectively, for parts, repairs, and             
          purchases for their vans and truck.  During each of those years,            
          petitioners also incurred expenses for gasoline for those vehi-             
          cles.                                                                       
               Petitioners received insurance proceeds during 1994 and 1995           
          in the amounts of $4,300 and $4,700, respectively, as reimburse-            
          ments for certain of Mr. Owens’ tools that he had used in his               
          painting business and that had been stolen in prior years.                  
          Petitioners had deducted the cost of those stolen tools on                  
          returns that they had filed prior to 1994 and 1995.                         
               During the years at issue, petitioners owned rental property           
          located in Toledo (Toledo rental property), which constituted               
          another source of income to them during those years.  Petition-             
          ers’ mortgage with respect to the Toledo rental property was held           
          by Mid American National Bank, and they also had a second mort-             
          gage on that property with Northriver Development Corporation.              






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