Charlie Daniel Turner, Jr. and Sandra Lovell Turner - Page 8




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          time.  She received medical attention for her illness until the             
          middle of 1997.                                                             
               Petitioners’ 1994 and 1996 joint Federal income tax returns            
          were timely filed.  Taking into account extensions, their 1995              
          joint Federal income tax return was due on or before October 15,            
          1996, but it was not filed until March 25, 1997.  Each return               
          includes a Schedule C for Turtle Performance.  The following                
          items are reported on the Schedules C:                                      
               Year             1994         1995         1996                        
               Income          $15,294      $22,505      $18,060                      
          Total expense   (59,739)     (73,079)     (56,727)                          
          deductions                                                                  
          Net profit      (44,445)     (50,574)     (38,667)                          
          or (loss)                                                                   
          The income for 1994 is attributable to leasing fees charged for             
          the use of petitioners’ tow vehicle and trailer.  For the most              
          part, the incomes reported for 1995 and 1996 consist of travel              
          expense reimbursements petitioner received from Nichols Research.           
          Some of the travel expense deductions claimed on the Schedules C            
          involve those trips when an open-road racing event coincided with           
          petitioner’s travel obligations as an employee of Nichols                   
          Research.                                                                   
               On Schedules C included with their Federal income tax                  
          returns from 1992, the year that Turtle Performance was                     









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