Neal N. and Ruby W. Viar - Page 4

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          their home.  As further described below, he also engaged in                 
          various additional activities to produce income.2  Mrs. Viar was            
          a bookkeeper.  Petitioners filed joint income tax returns,                  
          prepared by a return preparer, for 1999 and 2000.                           
               Mr. Viar was a licensed real estate agent.  He began selling           
          homes in 1995.  Prior to 1995, he was a contractor installing               
          water and waste treatment plants throughout Virginia.                       
               During the years at issue, Mr. Viar was an employee of CMH             
          Homes, Inc., on whose behalf he sold mobile homes.  In this                 
          activity during the years in question, Mr. Viar occasionally took           
          clients to lunch.  He did not keep detailed records of his meals            
          and entertainment expenses.  He used his own vehicle to show real           
          estate throughout five counties.  He did not keep a mileage log.            
               In a separate self-employed activity, Mr. Viar provided the            
          necessary amenities for the mobile homes sold by CMH Homes,                 
          including grading the land site, digging water wells, installing            
          the septic systems, constructing the brick underpinnings, and, in           
          some cases, installing a basement.  The work required travel to             
          county seats and to the location of each home.  Mr. Viar used his           
          own vehicle for these services, for which he was not reimbursed             

               2    Respondent did not argue that Mr. Viar’s additional               
          activities were activities not engaged in for profit under sec.             

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