Benjamin O. & Linda L. Agbaniyaka - Page 3




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          a concentration in taxation from Long Island University, was                
          employed full time by the Internal Revenue Service as a revenue             
          agent.  At all relevant times, Mr. Agbaniyaka was familiar with             
          the requirements of section 6001.                                           
               During the years 2001 through 2003, the State of New York              
          correctional system employed petitioner Linda L. Agbaniyaka (Ms.            
          Agbaniyaka).  In 2003, Ms. Agbaniyaka was diagnosed with a tumor            
          behind her right eye.  During that year, Ms. Agbaniyaka stopped             
          working for the State of New York correctional system.                      
               Petitioners began to report in Schedule C, Profit or Loss              
          From Business (Schedule C), for their taxable year 1988 income              
          and/or expenses with respect to certain activities relating to              
          African arts and crafts (claimed arts and crafts business).  As             
          part of those activities, Mr. Agbaniyaka traveled to various                
          trade shows across the United States.  In 1996, after Mr.                   
          Agbaniyaka suffered a heart attack, his doctor advised him to               
          limit his traveling.  Mr. Agbaniyaka followed his doctor’s advice           
          and ceased traveling long distances, including traveling to                 
          various trade shows across the United States.  In 2002, Mr.                 
          Agbaniyaka was diagnosed with sleep apnea, which made it danger-            
          ous for him to drive.  At all relevant times, Mr. Agbaniyaka also           
          limited his traveling in order to care for petitioners’ autistic            
          daughter.                                                                   
               During each of the years 2001 through 2004, Mr. Agbaniyaka             







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Last modified: November 10, 2007