William D. and Betty J. Boyd - Page 4

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          Mississippi or in any other State, except two burial plots in               
          Mississippi.  Petitioners have a daughter who lives in                      
          Mississippi, and all mail to petitioners is sent to the daughter.           
          Whatever mail she receives, she mails it to petitioners wherever            
          they happen to be.  Most of the mail is from churches throughout            
          the United States inviting petitioners to appear at their                   
          churches.  Petitioners occasionally visit Mississippi, and they             
          always stay as guests at the local church.  The local pastor is             
          also a contact person for persons interested in contacting                  
          petitioners. During the year at issue, petitioners visited                  
          Prentice, Mississippi, three times.                                         
               Petitioners, therefore, had no home in Mississippi that they           
          maintained and, accordingly, incurred no expenses in maintaining            
          a home.  Petitioners, however, contend that Mississippi is their            
          home, and all their friends and relatives consider petitioners’             
          home as Mississippi.                                                        
               Petitioners filed a joint Federal income tax return for                
          1999.  They thereafter filed at least two amended returns.  On              
          each return, petitioners included a Schedule C, Profit or Loss              
          From Business, on which they reported the income and expenses of            
          their ministerial activity.  On each of these returns, the                  
          expenses exceeded the reported gross income.  For the year at               
          issue, on the return that the Court believes represented the last           
          of the amended returns, petitioners reported Schedule C gross               






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