- 3 - 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. AgbaniyakaPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007