Patrick F. Philippi - Page 3

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               During 1999 or 2000, petitioner was not in business with his           
          brother-in-law, James Swanberg (Mr. Swanberg).  Over at least the           
          period 2000-2002, petitioner brought various lawsuits (peti-                
          tioner’s lawsuits) against Mr. Swanberg in the courts of Chisago            
          County, Minnesota (Minnesota courts).  In those lawsuits, peti-             
          tioner sought payment for a house that petitioner alleged he had            
          built with Mr. Swanberg.  The Minnesota courts dismissed all of             
          petitioner’s lawsuits.                                                      
               Petitioner filed Form 1040, U.S. Individual Income Tax                 
          Return, for each of his taxable years 1999 (1999 return) and 2000           
          (2000 return).                                                              
               Petitioner included Schedule A--Itemized Deductions (Sched-            
          ule A) as part of his 2000 return.  In that schedule, petitioner            
          claimed medical and dental expenses of $3,000, taxes paid of                
          $4,000, home mortgage interest and points paid of $7,000, and a             
          casualty or theft loss of $200,000 (claimed $200,000 Schedule A             
          loss).                                                                      
               Petitioner included Schedule C, Profit or Loss From Business           
          (Schedule C), as part of his tax return for each of the years               
          1999 (1999 Schedule C) and 2000 (2000 Schedule C).  Petitioner’s            
          1999 Schedule C showed gross receipts of $18,000 and claimed                
          various expenses totaling $18,300.  Petitioner’s 2000 Schedule C            
          showed $20,000 of gross receipts and claimed various expenses               
          totaling $20,000.  Petitioner’s 2000 Schedule C also claimed a              






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