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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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Last modified: November 10, 2007