Dale H. Sundby and Edith Littlefield Sundby - Page 6

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               Petitioners filed a Schedule C with their joint Federal                
          income tax return for taxable year 1994.  The Schedule C, which             
          named petitioner as the proprietor of a business engaged in                 
          “information services”, listed the following gross receipts and             
          deductions:                                                                 
               Gross receipts                            -0-                          
               Car and truck expenses                  $4,606                         
               Depreciation and section 179 expense    13,930                         
               Employee benefit programs                7,897                         
               Legal and professional services          6,379                         
               Office expense                          15,188                         
               Supplies                                 2,936                         
               Travel                                   9,443                         
               Meals and entertainment                  2,815                         
               Utilities                                3,706                         
               Home office expense                     22,169                         
               Net loss                               (89,069)                        
          Taking into account the Schedule C loss, petitioners reported               
          adjusted gross income of negative $80,020 and zero tax liability            
          for 1994.  Petitioners also filed a Form 1045, Application for              
          Tentative Refund, on which they requested a tentative refund for            
          1991 on account of a net operating loss (NOL) carryback from 1994           
          to that year of $81,923.  Respondent issued petitioners a refund            
          of $26,783 in accordance with this request.                                 
               In the notice of deficiency, respondent determined that                
          petitioners are not entitled to deduct the $89,069 claimed as               












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