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1989 Original 1991 1992 1993
Schedule C Joint 1990 Joint Joint Joint Joint
Relating to Return Return Return Return Return
Three Crowns ($99,414) ($98,176) ($91,122) –- –-
Hotel
Azure Tides Hotel (16,803)(5,899) (24,927) ($17,817) ($15,749)
Three Crowns (73,219) (73,212) (41,975) –- –-
Hotel Back Court
1 Linden Drive 2,100 –- –- –- –-
Petitioner’s law –- –- (7,502) (10,095) (8,526)
practice
Schedules C relating to the Three Crowns Hotel included as
part of the 1989 joint return and as part of the original 1990
joint return identified petitioner and Mr. Monsour as propri-
etors. Schedule C relating to that hotel included as part of the
1991 joint return identified Mr. Monsour as the proprietor.
Schedule C relating to the Azure Tides Hotel included as
part of each of the joint returns for the taxable years at issue
identified Mr. Monsour as the proprietor.
Schedules C relating to the Three Crowns Hotel Back Court
included as part of the 1989 joint return and as part of the
original 1990 joint return identified petitioner and Mr. Monsour
as proprietors. Schedule C relating to that motel included as
part of the 1991 joint return identified Mr. Monsour as the
proprietor.
Schedule C relating to 1 Linden Drive included as part of
the 1989 joint return identified petitioner as the proprietor and
showed “Medical Technician” as the principal business or profes-
sion. The net profit shown in that Schedule C resulted from
petitioner’s having performed certain bookkeeping tasks for
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