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F. Petitioner’s 1997 Income Tax Return
Petitioner filed a U.S. Individual Income Tax Return, Form
1040, for 1997, listing his occupation as “healing ministry”. On
his return, petitioner reported passive income from several
sources in the aggregate amount of approximately $68,000
(exclusive of tax-exempt interest and Social Security benefits),
and he claimed certain losses, including a “business loss” in the
amount of $46,851 for his “health, wealth and healing ministry”
activity. Petitioner reported a total tax liability of $844 on
his return.
In support of his claimed “business loss”, petitioner
attached to his return a Schedule C, Profit or Loss From
Business, for his “health, wealth and healing ministry” activity.
On his Schedule C, petitioner reported gross receipts, gross
profit, and gross income, all in the amount of $1,400. In
contrast, petitioner claimed expenses in the aggregate amount of
$48,251, consisting of the following:
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