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
During each of the years 2001 through 2004, Mr. Agbaniyaka
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Last modified: November 10, 2007