Edward W. and Edith M. Arnold - Page 5




                                         -5-                                          
         II. Disallowed Deductions and Other Amounts Claimed by                       
              Petitioners                                                             
              A.  Interest                                                            
              On Schedule E of their 2002 return, petitioners deducted                
         $10,045 in interest.  Neither petitioner paid any interest to                
         PCI.                                                                         
              B.  Labor Expenses                                                      
              On Schedules E of their 2002 and 2003 returns, petitioners              
         deducted $16,757 and $24,171, respectively, of labor expenses.               
         Respondent concedes that petitioners paid $3,122.52 in labor                 
         expenses for 2003 (attributable to services performed by William             
         Ray).                                                                        
              C.  Western Timber Farms, Inc.                                          
              On each of their 2002 and 2003 returns, petitioners claimed             
         a Schedule E loss relating to an entity known as Western Timber              
         Farms, Inc.                                                                  
              D.  Orion:  Cost of Goods Sold/Capital Loss                             
              On Schedule C, Profit or Loss From Business, of their 2002              
         return, petitioners claimed $40,000 in cost of goods sold related            
         to Orion Venture (Orion).  The “Principal business or                        
         professional activity code” entered on the Schedule C for Orion              
         is 523900, which the Schedule C instructions state is for “Other             
         financial investment activities (including investment advice)”.              
              On their 2002 and 2003 returns, petitioners indicated that              
         they did not have an interest in a financial account in a foreign            






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