Frank H. and Marla C. Black - Page 15




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          petitioners’ den.  The aquarium was set up the day before the               
          sixth birthday of petitioners’ son, Jonathan.  The aquarium                 
          remained in petitioners’ den until at least March 6, 1995.                  
          Mr. Black deducted the $1,150 paid for the aquarium as “Supplies”           
          on the Schedule C attached to the 1991 joint return.                        
               During 1992, Daniel Howachyn performed alterations on an               
          iron gate and also fabricated an arched door made of treated                
          wood.  Both the gate and door were located in petitioners’                  
          residential courtyard.  Mrs. Black paid for the work on the gate            
          with two checks of $425 and $200.  Mr. Black deducted both checks           
          to Mr. Howachyn as “Supplies” on the Schedule C attached to the             
          1992 joint return.                                                          
               During both 1991 and 1992, Mr. Black wrote checks to                   
          petitioners’ daughter, Anita Black, who was attending college at            
          the time.  A summary of these checks is as follows:                         
               Year      Amount         Stated Purpose                                
               1991      $900           Supplies                                      
               1991      $438           Supplies                                      
               1992      $102           Small overhead projector - supplies           
               1992      $375           Brother processor - supplies                  
               1992      $400           Typewriter - supplies                         
               1992      $500           Pay                                           
               1992      $500           Pay                                           
               1992       $300          Pay                                           
          Mr. Black deducted the foregoing eight checks based on their                
          “Stated Purpose” on the Schedule C attached to the 1991 and 1992            
          joint returns.  Anita Black never purchased equipment for or sold           








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