Gerard and Audrey Kathleen Hennessey - Page 11




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               On December 30, 1996, petitioners filed with the IRS a Form            
          1040 for the 1994 taxable year (1994 return).  On the 1994                  
          return, petitioners reported negative adjusted gross income of              
          $11,364 and an NOL carryforward of $51,284.  Petitioners reported           
          deductions for travel expenses of $9,258 and $24,847 on Form 2106           
          and Schedule C, respectively.  On the Schedule C for ISOA                   
          Consulting, petitioners included “Royalties paid” of $46,200 as             
          part of the cost of goods sold.  Petitioners also claimed                   
          multiple deductions for some of the same expenses on the 1994               
          return.                                                                     
               In August 1997, petitioners sent to the IRS a second Form              
          1040 for the taxable year 1994 with the word “Revised” written at           
          the top of the first page, as well as on several attached pages             
          (1994 “Revised” return).  On the 1994 “Revised” return,                     
          petitioners reported deductions for travel expenses of $5,101 and           
          $29,533 on Form 2106 and Schedule C, respectively.                          
               On the Schedules C for ISOA Consulting attached to the 1994            
          returns sent to respondent, petitioners reported the following              
          amounts:                                                                    
                                   1994           1994                                
                                   Return1      “Revised” return                      
               Gross income        ($2,692)       $13,055                             
               Total expenses      (42,272)       (34,939)                            
               Net loss            (44,964)           2(20,344)                       
               1  As noted by petitioners on both the Schedule C and Schedule E, Supplemental Income
               and Loss, attached to the 1994 return, these amounts included petitioners’ portion
               of the gross receipts and expenses from ISOA, Inc.                     
               2  This amount is a mathematical error and should have been $21,884.   





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