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On December 30, 1996, petitioners filed with the IRS a Form
1040 for the 1995 taxable year (1995 return). On the 1995
return, petitioners reported adjusted gross income of $25,439 and
an NOL carryforward of $50,132. Petitioners claimed deductions
for travel expenses of $9,428 and $21,565 on Form 2106 and
Schedule C, respectively. Petitioners again claimed multiple
deductions for some of the same expenses.
On or about March 14, 1997, respondent received a second
Form 1040 from petitioners for the taxable year 1995 with
“Amended” written at the top of the first page (1995 “Amended”
return). On the 1995 “Amended” return, petitioners reported
adjusted gross income of $6,395. Petitioners also reported
deductions for travel expenses of $14,586 on both the Form 2106
and Schedule C.
On or about August 18, 1997, respondent received a Form 1040
from petitioners for the 1996 taxable year. On the 1996 return,
petitioners reported adjusted gross income of $16,529 and an NOL
carryforward of $36,157. On a Schedule A, Itemized Deductions,
petitioners claimed a deduction for “Job travel: accom. in
Dallas” in the amount of $59,479. Petitioners also claimed a
deduction for travel expenses on Form 2106 of $36,714. On the
Schedule C for ISOA Consulting attached to the 1996 return,
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Last modified: November 10, 2007