Frank H. and Marla C. Black - Page 16

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          any equipment to Mr. Black.  Although Anita Black occasionally              
          did some work for her father’s business, she never received a               
          paycheck.  Anita Black did have a Brother processor and                     
          typewriter and used them for schoolwork.  Mr. Black did not issue           
          a Form 1099 or Form W-2, Wage and Tax Statement, for the $1,300             
          allegedly paid to Anita Black as wages during 1992.                         
               For 1991 and 1992, petitioners claimed Schedule C deductions           
          for travel expenses of $43,084 and $18,272, respectively, and               
          claimed Schedule C deductions for meals and entertainment of                
          $29,561 and $14,734, respectively.                                          
               For many years, Mr. Black has placed title to his property             
          solely in his wife’s name because of his concerns that his                  
          property could be reached by potential creditors.                           
               Mrs. Black holds a bachelor of visual arts degree in                   
          sculpture.  Mrs. Black did not personally sign the 1991 and 1992            
          joint returns.  Mr. Black signed Mrs. Black’s name to the 1991              
          and 1992 joint returns.  Mrs. Black did not review, and never               
          saw, the 1991 or 1992 joint returns before they were filed.  She            
          also never asked Mr. Black whether he had timely filed those                
          returns and did not know until well after the fact that those               
          returns had been filed.                                                     

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