Charlie Daniel Turner, Jr. and Sandra Lovell Turner - Page 3




                                        - 2 -                                         
               Respondent determined deficiencies in and an addition to               
          petitioners’ Federal income taxes as follows:                               
                    Year           Deficiency          Sec. 6651(a)(1)                
                    1994            $10,909                 --                        
                    1995             11,571          $2,322                           
                    1996              6,828            --                             
               The issues for decision are: (1) Whether expenses listed on            
          Schedule C, Profit or Loss From Business, included with                     
          petitioners’ Federal income tax return for each year in issue               
          were incurred in an activity for profit; (2) whether income                 
          received and expenses incurred during 1994 by petitioners’                  
          daughter are properly reportable on petitioners’ return for that            
          year; and (3) whether petitioners had reasonable cause for                  
          failing to file a timely 1995 return.                                       
          Background                                                                  
               Some of the facts have been stipulated and are so found.               
          Petitioners are husband and wife.  They filed a joint Federal               
          income tax return for each year in issue.  At the time the                  
          petition was filed, petitioners resided in Ardmore, Alabama.                
          References to petitioner are to Charlie Daniel Turner.                      
               Petitioner has a doctorate in aerospace engineering.  At               
          all relevant times he was employed on a full-time basis as an               
          aerospace engineer by Nichols Research Corporation (Nichols                 
          Research).  He was required to travel extensively in connection             
          with this employment.  His traveling expenses, including                    






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011