- 6 -
then, JJT has reported net profits every year, as summarized in
this table:2
Cost of Net Profit
Year Receipts Goods Sold Expenses or Loss
1988 $7,566 $5,149 $4,091 ($1,674)
1989 4,250 6,141 1,649 (3,540)
1990 6,060 9,188 2,081 (5,209)
1991 6,135 5,801 6,621 (6,287)
1992 7,805 6,109 4,802 (3,106)
1993 6,060 5,677 9,389 (9,006)
1994 7,019 5,493 12,051 (10,525)
1995 7,124 -0- 7,016 108
1996 13,470 -0- 12,294 1,176
1997 14,426 -0- 13,200 1,226
1998 13,075 -0- 11,936 1,139
For the years in issue, JJT’s gross revenues were
attributable to PSI and other sources (principally photography
exhibitions) as follows:
Gross Income Gross Income
Year from PSI from Other Sources
1993 $6,060 --
1994 6,060 $959
1995 2,460 4,664
For taxable years 1996 through 1998, producing photography
exhibitions was the sole source of revenue for JJT.
For the years in issue, petitioner claimed the following
costs of goods sold and deductions on his Schedules C, Profit or
Loss From Business (Sole Proprietorship) (Schedule C):
2 The record does not indicate the amount of JJT’s losses or
other relevant tax information for years before 1988.
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