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At several stages in petitioner’s career as a businessman
and consultant, petitioner was exposed to the food and drink
franchise industry and worked with some of the largest franchise
operators in the world, including McDonald’s Corporation.
Petitioner also earned a master’s degree in business
administration with a concentration in marketing and finance from
the University of Chicago in 1989.
On his Form 1040 for 2001, petitioner reported wages of
$217,771. Petitioner attached a Schedule C to his Form 1040 for
2001. On his Schedule C for 2001, petitioner claimed business
deductions of $55,348, zero gross receipts or sales, and other
income of $161. On the Schedule C for 2001, petitioner reported
the business name as “Tasha’s” and the principal business or
profession as “Retail”.
On his Form 1040 for 2002, petitioner reported wages of
$188,468. Petitioner attached a Schedule C to his 2002 income
tax return, reporting $48,001 of business deductions, zero gross
receipts or sales, and other income of $43. On the Schedule C
for 2002, petitioner reported the business name as “Tasha’s” and
the principal business or profession as “Wine Distribution/
Retail”.
On June 8, 2005, respondent sent petitioner the above-
mentioned notice of deficiency. Respondent attached to the
notice of deficiency copies of Form 4549A, Income Tax Examination
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