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Mena’s Arco (Mena’s), in San Bernardino, California, as a sole
proprietorship during the years in issue. Mena’s sold gasoline
and other merchandise such as snacks, lottery tickets,
cigarettes, and automotive parts and supplies. Mena’s received
commissions on repair work completed by third parties. There
were two public telephones on Mena’s premises that paid Mena’s a
commission.
Petitioners’ Federal Returns
Petitioners filed Form 1040, U.S. Individual Income Tax
Return, for 1993 reporting adjusted gross income of $12,282 and
taxable income of $0. Petitioners claimed an earned income
credit of $1,311. Petitioners filed a Schedule C, Profit or Loss
From Business, reporting gross receipts of $4,963,722, expenses
of $4,956,469, and a net profit of $7,253 that was reported on
their Form 1040.
Petitioners filed a Form 1040 for 1994 reporting adjusted
gross income of $14,523 and taxable income of $0. Petitioners
claimed an earned income credit of $1,904. Petitioners filed a
Schedule C reporting gross receipts of $4,668,333, cost of goods
sold of $4,219,896, expenses of $346,907, and a net profit of
$15,627 that was reported on their Form 1040.
Petitioners filed a Form 1040 for 1995 reporting adjusted
gross income of $15,717 and taxable income of $0. Petitioners
claimed an earned income credit of $2,214. Petitioners filed a
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