John G. and Janice E. Parker - Page 4




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               During 1995 and 1996, petitioner sold six or seven of his              
          direct ignition systems for use in experimental aircraft for                
          approximately $1,900 to $3,000 each.                                        
               In December of 1996, petitioner obtained from the City of              
          Reno, Nevada, a general business license relating to his airplane           
          activity.                                                                   
               Also in 1996, petitioner leased property in Reno, Nevada, on           
          which petitioner constructed a 7,000-square foot hangar to be               
          used as a place to build and work on his airplanes.                         
               In 1998, petitioner retired from American.                             
               On a Schedule C, Profit or Loss From Business, filed with              
          petitioners’ joint Federal income tax returns for 1989 through              
          1999 that were prepared by an accountant, petitioners reported              
          gross income, ordinary business expenses, and net losses relating           
          to petitioner’s airplane activity, and unrelated wage and taxable           
          pension and annuity income as follows:                                      
                                                                                     
          Unrelated                                                                   
                              Airplane Activity            Wages,                     
          Pensions,                                                                   
               Year   Gross Income   Expenses    Net (Loss)    & Annuities            
              1989     $ 3,048      $ 83,216    ($ 80,168)    $  169,433             
              1990       7,119        45,000      (37,881)       166,643             
              1991       4,944        49,930      (44,986)       186,683             
              1992       1,596        78,367      (76,771)       180,683             
              1993       9,942       112,549     (102,607)       188,829             
              1994       2,002        80,899      (78,897)       182,590             
              1995       3,810        76,826      (73,016)       183,415             
              1996      10,390        76,277      (65,887)       185,770             
              1997      22,545        82,673      (60,128)       206,506             
              1998      23,773       103,889      (80,116)       110,844             
              1999       5,402        88,713      (83,311)       202,559             
               TOTAL    $94,571      $878,339    ($783,768)    $1,963,955             





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