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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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