Verna Doyel - Page 9

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          Christopher also subtracted $645 in adjustments to income to                
          arrive at adjusted gross income.  The total tax listed was zero.            
          The Federal income tax withheld listed was $6,609.  The Tax                 
          Office of W.J. Hoyt Sons Management Co. was listed as the return            
          preparer on the 1984 return.                                                
               On their joint income tax return for 1985, petitioner and              
          Christopher reported $49,748 in wages.  In arriving at total                
          income, the only additions and subtractions were $1,022 in                  
          interest income, $300 in dividends, an $8 capital gain, and a               
          $23,719 Schedule E loss.  This Schedule E loss ($20,180) was                
          mostly attributable to petitioner and Christopher’s investment in           
          SGE 1984-2.  Petitioner and Christopher also subtracted $2,609 in           
          employee business expenses to arrive at adjusted gross income.              
          The total tax listed was zero.  The Federal income tax withheld             
          listed was $1,703.  The Tax Office of W.J. Hoyt Sons Management             
          Co. was listed as the return preparer on the 1985 return.                   
               On their joint income tax return for 1986, petitioner and              
          Christopher reported $50,407 in wages.  In arriving at total                
          income, the only additions and subtractions were $237 in interest           
          income, $691 in dividends, a $1 capital gain, and a $22,620                 
          Schedule E loss.  This Schedule E loss ($20,180) was mostly                 
          attributable to petitioner and Christopher’s investment in SGE              
          1984-2.  Petitioner and Christopher also subtracted $1,523 in               
          employee business expenses and a $2,000 IRA deduction to arrive             
          at adjusted gross income.  The total tax listed was $240.  The              




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