Alber I. and Georgette H. Said - Page 3

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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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