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business by stating that its name was “Complete Connections”, it
was owned by her and petitioner James Snyder (James Snyder), its
business was “Income Tax/Accounting”, and it was a sole
proprietorship. On August 31, 1992, she applied for a renewal
business license for the business named “Complete Connections”,
again stating that it was owned by her and James Snyder, and
describing its business as “Computerized Accounting and Tax
Services”. On January 10, 1996, James Snyder filed a statement,
“Fictitious Business Name Statement”, with the County of San Luis
Obispo, California. In that statement, Mr. Snyder stated that
the fictitious business name was “Complete Connections Computer
Systems”, the name of the registrant was “James D. Snyder”, and
the business in question was conducted by an individual.
Petitioners’ Federal Income Tax Returns
For 1991, petitioners made a joint return of income on
Form 1040, U.S. Individual Income Tax Return (the 1991 Form
1040). Attached to the 1991 Form 1040 is a Schedule C, Profit or
Loss From Business (Sole Proprietorship) (the 1991 Schedule C).
On the 1991 Schedule C, petitioners state that they are the
proprietors of a business named “Complete Connections”, the
business of which is computer sales, bookkeeping, and taxes. The
1991 Schedule C shows gross receipts of $228,858, cost of goods
sold of $113,974, other income of $186, expenses of $82,267, and
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