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1980, 1981, and 1982, Mr. Drowns prepared their returns. For
1983, 1984, 1985, and 1986, the Hoyt organization prepared their
returns.
On their joint income tax return for 1980, petitioner and
Mr. Bartak reported $39,188 in wages. In arriving at total
income, the only additions and subtractions were $565 in interest
income, $577 in taxable refunds of State and local taxes, and a
$5,205 Schedule E, Supplemental Income Schedule, loss. This
Schedule E loss was attributable to petitioner and Mr. Bartak’s
investment in a non-Hoyt partnership. The total tax listed was
$3,664. The Federal income tax withheld listed was $4,631.
On their joint income tax return for 1982,4 petitioner and
Mr. Bartak reported $48,797 in wages. In arriving at total
income, the only additions and subtractions were $312 in interest
income, $14 in dividends, $570 in taxable refunds of State and
local taxes, and a $1,017 Schedule E loss. This Schedule E loss
was attributable to petitioner and Mr. Bartak’s investment in a
non-Hoyt partnership. The total tax listed was $5,714. The
Federal income tax withheld listed was $5,641.
On their joint income tax return for 1983, petitioner and
Mr. Bartak reported $53,827 in wages. In arriving at total
income, the only additions and subtractions were $302 in interest
income, $59 in dividends, $541 in taxable refunds of State and
4 Petitioner’s 1981 joint return is not part of the record.
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