- 5 - Proprietorship), reporting the income, expenses, and profit or loss from petitioner’s law practice. Petitioner’s Schedules C listed gross income, deductions, and net profit (loss) in the following amounts: Year Gross income Deductions Net profit (loss) 1987 $75,097 $76,198 $(1,101) 1988 128,896 121,459 7,437 1989 124,463 115,690 8,773 1990 95,730 124,543 (28,813) II. Respondent’s Adjustments to Petitioner’s Schedule C Income and Deductions in the Notices of Deficiency A. Adjustments to Income Respondent increased petitioner’s Schedule C gross income4 for the years in issue in the following amounts: Year Adjustment 1987 $77,811 1988 117,819 1989 116,483 1990 154,069 Respondent based the adjustments to petitioner’s Schedule C gross income on two personal financial statements that petitioner submitted to American National Bank (ANB) in St. Paul (the financial statements). Petitioner submitted the first financial statement, dated December 22, 1987 (the 1987 financial statement), in connection with her purchase of a home and the 4Petitioner’s gross income equaled her gross receipts in each of the years at issue because she was a cash basis taxpayer and had no cost of goods sold during those years.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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