Michael J. Rozzano, Jr., and Rose Marie Rozzano - Page 5




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               Between 1993 and 2000, petitioners reported the following              
          amounts of income and expenses from their activities at Sugar               
          Tree on their Schedules C, Profit or Loss From Business:                    
                              1993        1994     1995      1996                     
          Gross receipts      $61,728   $56,352   $47,952   $92,267                   
          Expenses            116,972   116,859   104,580   128,580                   
          Net profit/(loss) (55,244) (60,507)     (56,628) (36,313)                   
                               1997      1998      1999      2000                     
          Gross receipts      $65,826   $92,267   $53,204   $58,109                   
          Expenses            134,491   161,047   147,894   149,834                   
          Net profit/(loss) (68,665) (68,780) (94,690) (91,725)                       
               During the taxable years in issue, petitioners reported                
          income on their Federal income tax returns as follows:                      
                                   1999                          2000                 
          Wages, salaries, tips      $221,968.18       $159,018.45                    
          Taxable interest              690.94         1,749.32                       
          Tax-exempt interest           36.57                85.22                    
          Ordinary dividends              984.96             1,067.51                 
          Taxable refunds          437.00             2,490.00                        
          Business income or loss     (94,690.06)          (91,722.66)                
          Capital gain or loss     (3,000.00)               (2,817.05)                
          Pensions and annuities        ROLLOVER             ROLLOVER                 
               Total               $126,427.59          $69,870.79                    
               During the taxable years in issue, petitioners claimed the             
          following business expenses1 on their Schedules C:                          
                                   1999                     2000                      
          Advertising              $105                $0                             
          Car and truck expenses   3,906                    0                         
          Insurance                1,865               2,859                          
          Interest                 2,634               5,368                          
          Office expenses          2,787               1,230                          

               1 These figures have been rounded to the nearest dollar.               






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