Gerard and Audrey Kathleen Hennessey - Page 9




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          which included the incorporation of ISOA, Inc., and petitioner’s            
          competing work and travel demands, as well as a family crisis.              
          On December 18, 1994, after being contacted by the IRS,                     
          petitioners sent a reply letter to the IRS which stated that                
          they planned to have their 1992 and 1993 returns completed by               
          January 15, 1995.  Petitioners testified that their work                    
          responsibilities, as well as personal concerns, prevented them              
          from completing their 1992 and 1993 returns by their self-imposed           
          January 15, 1995, deadline.                                                 
               On or about March 1, 1995, respondent received a second Form           
          1040 for the 1992 taxable year which again had “Estimated”                  
          written on the top of the first page.                                       
               On or about October 1, 1996, petitioners submitted an                  
          unsigned Form 1040 to the IRS for the taxable year 1993 (1993               
          unsigned return).                                                           
               On December 30, 1996, petitioners filed a Form 1040 for the            
          1993 taxable year (1993 return).  On the 1993 return, among other           
          items, petitioners: (1) Reported a net operating loss (NOL)                 
          carryforward deduction from 1992 of $18,347; (2) claimed a                  
          deduction for travel expenses of $13,016 on Form 2106, Employee             
          Business Expenses; and (3) deducted $17,293 of travel expenses on           
          the Schedule C, Profit or Loss From Business, for ISOA                      
          Consulting.                                                                 








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