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Respondent determined a deficiency in petitioners' 1996
Federal income tax in the amount of $2,144.
The issue for decision is whether petitioner George Steven
Sasser received unreported income in his business as a self-
employed carpet installer. We hold that he did to the extent set
forth below.
Background
Some of the facts have been stipulated, and they are so
found. Petitioners resided in DeFuniak Springs, Florida, at the
time that their petition was filed with the Court.
Petitioners are a married couple. Throughout the year in
issue, petitioner wife (Mrs. Sasser) was a licensed practical
nurse and petitioner husband (Mr. Sasser) was a self-employed
carpet installer. Mrs. Sasser maintained the family accounts and
assisted Mr. Sasser in keeping records related to the income and
expenses of his business.
Mr. Sasser installed carpets for Evans Carpet City (Evans
City) of DeFuniak Springs, Florida, and he may also have
installed carpets for one or more homebuilders. Evans City sold
both residential and commercial carpeting and utilized the
services of several different installers to lay carpet that it
sold.
Evans City and Mr. Sasser followed an established business
practice whereby Evans City would contact Mr. Sasser when an
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