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petitioner’s Forms 1040, U.S. Individual Income Tax Return, for
1991-94. On his returns, petitioner reported his adjusted gross
income as follows:
1991 1992 1993 1994
Wages, salaries, tips, etc.$7,692 $8,294 $7,267 $6,078
Interest 822 233 233 3,258
Dividends 18 22 28 32
Capital gain (loss) (143) (143) (143) --
Other gains (losses) –- 3,729 57 63
Rents, royalties, etc. 11,056 11,056 11,183 13,998
Farm income (loss) (14,988) (10,051) (6,766) (6,073)
Net operating loss c/o (16,853) (15,653) (5,970) -–
Adjustments to income –- –- –- –-
Adjusted gross income (12,396) (2,513) (5,889) 17,356
On the Schedules F, Profit or Loss From Farming, of his
returns, petitioner reported net farm losses for 1991-94 as
follows.
1991 1992 1993 1994
Income
Sales of products raised $90,887 $121,038 $87,642 $55,182
Cooperative distributions 22 -- 69 --
Agricultural program
payments 13,310 14,554 28,317 44,927
Crop insurance proceeds 14,123 -- -- --
Other income 288 281 377 458
Gross income 118,630 135,873 116,405 100,567
Expenses (133,618) (145,924) (123,171) (106,640)
Net farm profit (loss) (14,988) (10,051) (6,766) (6,073)
In April 1998, petitioner was indicted in the U.S. District
Court for the District of Minnesota on four counts of filing
false tax returns in violation of section 7206(1). The
indictment charged that for 4 separate years (1991-94) petitioner
willfully made and subscribed to Federal income tax returns
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