Wayne Robert and Patricia A. Rogers - Page 4




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         (Bainbridge).  The Bainbridge office was located south of Route              
         128 in Canton, Massachusetts, within the Boston metropolitan                 
         area.                                                                        
              Except for days on which he was traveling for Bainbridge                
         outside of Massachusetts, petitioner commuted from his home in               
         Wilmington, a community proximate to Route 128 and within the                
         Boston metropolitan area, to the Bainbridge office in Canton.                
         Petitioner’s commute typically took 45 minutes in the morning and            
         anywhere from 45 minutes to 1-� hours in the evening.                        
              At least when he was not traveling for Bainbridge outside of            
         Massachusetts, petitioner’s typical workweek consisted of 45 to              
         48 hours.  The vast majority of this time was spent at the                   
         Bainbridge office in Canton.  Petitioner spent relatively little             
         time working at home.                                                        
              B.  Petitioners’ Income Tax Returns                                     
              Petitioners timely filed joint Federal income tax returns               
         for 1997 and 1998.  In each instance, petitioners attached to                
         their returns a Schedule C, Profit or Loss From Business, for                
         petitioner’s business as a computer consultant.                              
              Petitioner reported income and claimed expenses on his                  
         Schedules C for 1997 and 1998 as follows:                                    
              1997             1998                                                   
              Gross income             $108,394.70       $97,614.34                   
              Less: total expenses      -20,364.10       -18,218.09                   
              Net profit                 88,030.60        79,396.25                   







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