Verna Doyel - Page 8

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          from Florida Power Corp. reporting $38,889.90 in wages.  In                 
          arriving at total income and adjusted gross income, the only                
          subtractions were a $426.06 Schedule C, Profit or (Loss) From               
          Business or Profession, business loss and a $577.65 Schedule E,             
          Supplemental Income Schedule, loss.  The total tax listed was               
          $4,160.  The Federal income tax withheld listed was $5,225.34.              
          Christopher prepared the 1982 return.                                       
               On their joint income tax return for 1983, petitioner and              
          Christopher reported $42,570 in wages.  Attached to this return             
          was a Form W-2 for Christopher from Florida Power Corp. reporting           
          $42,363.66 in wages.  In arriving at total income and adjusted              
          gross income, the only additions and subtractions were $214.21 in           
          interest income, an $800.50 Schedule C business loss, and a                 
          $753.62 Schedule E loss.  The total tax listed was $5,102.  The             
          Federal income tax withheld listed was $5,741.01.  Christopher              
          prepared the 1983 return.                                                   
               On their joint income tax return for 1984, petitioner and              
          Christopher reported $47,234 in wages.  Attached to this return             
          was a Form W-2 for Christopher from Florida Power Corp. reporting           
          $47,096.20 in wages and a Form W-2 for petitioner from “Mad.                
          Health Spa of St Pete, Inc” reporting $138.32 in wages.  In                 
          arriving at total income, the only additions and subtractions               
          were $92 in interest income and a $30,270 Schedule E loss.  This            
          Schedule E loss was entirely attributable to petitioner and                 
          Christopher’s investment in SGE 1984-2.  Petitioner and                     




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