Charlie Daniel Turner, Jr. and Sandra Lovell Turner - Page 14




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          acknowledged; that is, car racing at any level is an expensive              
          proposition.7  Lastly, giving little weight to petitioner’s offer           
          to sell the Mustang at prices that increased based upon the                 
          accomplishments achieved, we have serious doubts whether the                
          value of the Mustang would ever exceed the cumulative losses                
          incurred by petitioners over the history of Turtle Performance.             
          It follows that respondent’s adjustments disallowing the net loss           
          claimed on the Schedule C for Turtle Performance for each year in           
          issue are sustained.                                                        
               Petitioners’ 1994 return also includes a Schedule C                    
          reporting income earned and expenses incurred by their minor                
          child.  Respondent determined that neither the income nor the               
          expenses are properly reported on petitioners’ joint return.  We            
          agree.  In general, amounts received in respect of services                 
          rendered by a child are includable in the child’s income and not            
          in the income of the child’s parents.  Sec. 73(a).  Furthermore,            
          expenditures attributable to such income are generally treated as           
          paid or incurred by the child.  Sec. 73(b).  Respondent’s                   
          adjustments in this regard are therefore sustained.                         
               Taking into account successive extensions, petitioners’ 1995           
          joint Federal income tax return was due on or before October 15,            


               7 The late Colin Chapman, founder and guiding force of Lotus           
          Cars, Ltd., is rumored to have said that he made a small fortune            
          from automobile racing.  The problem, according to Mr. Chapman,             
          was that when he started racing he had a large fortune.                     






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