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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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