Tommy Owens, Jr. and Dawn R. Owens - Page 10




                                       - 10 -                                         
          their joint return for 1991 was equal to the loss they claimed in           
          Schedule C of that return, reduced by $39 of taxable interest               
          that they reported in that return.  The loss that petitioners               
          reported in their joint return for 1992 was equal to the loss               
          that they claimed in Schedule C of that return.                             
          On December 27, 1996, petitioners filed a joint return for                  
          taxable year 1993, which showed a loss of $6,520.  On December              
          26, 1996, petitioners filed joint returns for taxable years 1994            
          and 1995, which showed losses of $1,729 and $35,532, respec-                
          tively.  The loss that petitioners reported in their joint return           
          for each of the years at issue was equal to the total of the loss           
          claimed in Schedule C and the loss claimed in Schedule E, Supple-           
          mental Income and Loss (Schedule E), of each such return.                   
               In Schedules C of petitioners’ joint returns for 1993, 1994,           
          and 1995, petitioners reported (1) Schedule C gross receipts of             
          $66,779, $112,610, and $152,870, respectively; (2) Schedule C               
          cost of goods sold of $24,121, $64,514, and $91,607, respec-                
          tively; (3) Schedule C gross income of $42,658, $48,096, and                
          $61,263, respectively; (4) Schedule C expenses of $46,510,                  
          $48,813, and $93,953, respectively; and (5) Schedule C losses of            
          $3,852, $717, and $32,690, respectively.  Included within the               
          claimed Schedule C cost of goods sold for the years 1993, 1994,             
          and 1995 was claimed cost of labor in the amounts of $20,766,               








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