Robert D. and Patricia M. Braun - Page 3

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          and advertising expenses of less than $2,0002) for a net profit             
          of $1,447.                                                                  
               In July 1990, the Federal Bureau of Investigation (FBI)                
          conducted a raid on a company petitioner operated at that time              
          and seized all the company's business records.  Sometime after              
          the seizure, petitioner commenced operation of the real estate              
          loan business that generated the gross receipts petitioners                 
          reported for 1992 and 1993.  The FBI's investigation of                     
          petitioner continued until October 24, 1994, when petitioner pled           
          guilty to one count of tax evasion under section 7201 with                  
          respect to his 1988 taxable year and one count of mail fraud.  On           
          January 17, 1995, petitioner was sentenced to 24 months of                  
          incarceration with supervised release for 3 years thereafter.               
          Sometime later in 1995, while petitioner was incarcerated, the              
          FBI returned petitioner's seized records to Mrs. Braun.                     
               Petitioners' 1992 and 1993 Federal income tax returns were             
          dated and signed April 12, 2001, and were filed with respondent             
          on April 20, 2001.  Respondent disallowed all of petitioners'               
          claimed Schedule C expenses for 1992 and 1993 and issued                    
          petitioners a notice of deficiency on April 5, 2004.  Petitioners           




               2 Because of the poor quality of the copy of petitioners'              
          1993 Schedule C in the record, we are unable to determine the               
          exact amount of advertising expenses petitioners claimed, but               
          note that it appears to be approximately $1,800.                            





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