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Some of the facts were stipulated. Those facts and the
accompanying exhibits are so found and are incorporated herein by
reference. Petitioner's legal residence at the time the petition
was filed was Taft, California.
Petitioner was engaged in a loan brokerage business, wherein
he arranged mortgage loan refinancing between customers and
various lending institutions. He conducted this activity for
approximately 16 years. Petitioner received commissions for his
services based on varying percentages of the amount of the loans
involved. At the time of trial, petitioner was no longer engaged
in this activity.
Petitioner and his wife, Freddie T. Franklin, filed a joint
Federal income tax return for 1996. The income and expenses
related to petitioner's loan brokerage business were reported on
a Schedule C, Profit or Loss From Business. For 1996, petitioner
and his spouse reported on Schedule C gross income of $15,100,
expenses of $28,223, and a net loss of $13,123. In the notice of
deficiency, respondent adjusted some of the expenses as follows:
3(...continued)
petitioner contended otherwise.
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