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activities included processing the orders of other wholesalers or
retailers.
Mrs. Dunnegan worked 30 to 45 hours per week for Auto Plaza
performing accounting, preparing title work, and preparing sales
tax reports. She also spent about 25 to 40 hours per week on
activities related to the fireworks businesses, except between
May and July when she worked 50 hours or more per week in the
fireworks businesses. Mrs. Dunnegan’s duties that were related
to the fireworks activities were conducted in her home and
consisted of accounting and bookkeeping services, determining the
orders for the following year, placing the overseas orders,
helping to pack the orders, and monitoring shipments.
Mrs. Dunnegan performed 100 percent of the bookkeeping for the
Moriarty store.
The fireworks businesses are operated as sole
proprietorships, and the income and expense for each location is
reported on a Schedule C, Profit or Loss From Business. On
petitioners’ Schedules C for 1993, both Mr. and Mrs. Dunnegan are
listed as the proprietors of the Moriarty, Dennings, and Kansas
City fireworks businesses. Petitioners attributed 50 percent of
the net profit and loss from these fireworks businesses to
Mrs. Dunnegan.
J&G Enterprise is a sole proprietorship of Mr. Dunnegan that
engages in the sale of fireworks. The income and expenses of the
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Last modified: May 25, 2011