Paul D. and Gudrun G. Weaver - Page 3

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          was filed in this case, petitioners resided in Weston, Connecticut.         
               Petitioners, husband and wife, filed a joint Form 1040, U.S.           
          Individual Income Tax Return, for the taxable year 1998.  The               
          return was filed on January 7, 2000, with the Internal Revenue              
          Service in Andover, Massachusetts.  Petitioners reported wage               
          income of $140,316, and attached to the return Forms W-2, Wage              
          and Tax Statement, showing wages paid by Marketing Concepts                 
          Group, Inc., of $139,446.44 to Mr. Weaver and $870 to Mrs.                  
          Weaver.  Petitioners also included with their return two                    
          Schedules C and the pertinent (second page) portion of a Schedule           
          E, Supplemental Income and Loss.                                            
               On June 25, 1996, previous to filing their 1998 return and             
          presumably in connection with an earlier audit, petitioners had             
          received from the Internal Revenue Service a fax listing several            
          recommendations with respect to petitioners’ tax reporting.                 
          Among other things, the fax directed that petitioners should                
          “maintain separate Schedule C’s [sic] for all different business            
          activities.”                                                                
               The two Schedules C accompanying petitioners’ 1998 return              
          both list Mr. Weaver as the proprietor of the business and give a           
          business address identical to that of petitioners’ residence.               
          One Schedule C is for a marketing business with the name shown as           
          “Marketing Concepts Group/dba”.  That Schedule C reflects $95,841           








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