Della H. Knorr and Duane J. Knorr - Page 6

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          December 2, 1996.  The IRS received the 1991 return on                      
          December 5, 1996.  Martinez prepared the 1991 return.                       
               On their joint income tax return for 1992 (1992 return),               
          petitioner and intervenor reported the following sources of                 
          income and loss:                                                            
                           Source              Amount of Income (Loss)                
             Taxable interest                             $290                        
             Dividends                                   5,041                        
             Net short-term capital gain                 6,243                        
             Long-term capital loss carryover          (70,107)                       
             Other losses                               (5,381)                       
             Universal Painters                        252,847                        
             Atrium Homes & Development                (40,813)                       
          Petitioner and intervenor received the dividends that they                  
          reported on the 1992 return from the following sources:                     
          “Founders Money Market” and “Bedford Money Market”.  Petitioner             
          and intervenor reported taxable income of $184,961 and total tax            
          of $50,089 for 1992.  Petitioner and intervenor signed the 1992             
          return on December 2, 1996.  The IRS received the 1992 return on            
          December 5, 1996.  Martinez prepared the 1992 return.                       
               On their joint income tax return for 1993 (1993 return),               
          petitioner and intervenor reported the following sources of                 
          income and loss:                                                            












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