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    11 -

75,657

53,804

60,072

(51,879)

(27,527)

(42,829)

(6,025)

(11,362)

(4,674)

17,753

14,915

12,569

Consulting business Schedule C Income Expenses Expense for business use of home Net profit

1994

1995

1996

-0-

-0-

(336,981)

3,536 148 106,322 -- 283 236 7,196 3,659 586 121,966 (121,966)

27,525 -- 33,487 1,357 500 -- -- 9,677 -- 72,546 (72,546)

-- -- -- 8,242 -- -- -- -- -- 8,242 (345,223)

(776) (2,655) (3,431)

-0- (809) (809)

-0- (1,578) (1,578)

$355,966 and closing inventory of

$18,985 for which he reported cost of goods not attach an explanation as to why the different from the 1995 closing inventory.

sold

of $336,981.

Petitioner

did

1996

beginning

year

inventory

was

Property management Schedu Income1 Expenses Depreciation Insurance Mortgage interest Other interest Legal Office expense Repairs and maintenance Taxes and licenses Travel Total Net profit (loss) Distributorship Schedule C Income Expenses Net profit (loss)

le C

1For 1994 and 1995, petitioner reported no inventory at the beginning

and close of each estate dealership

year with business.

respect to For 1996,

the property management and real he reported opening inventory of

In December 1997, the IRS began an examination of

petitioner’s

1994-96

returns.

On

December

21,

1998,

respondent

issued petitioner and Mrs. Wood a notice of deficiency for 1994.

On July 19, 1999, respondent issued them a notice of deficiency

for

1995-96.

In

the

notices

of

deficiency,

respondent

(1)

increased the capital gain on the sale of the New Jersey house by

$14,117 ($90,888 rather than the $76,771 reported on petitioner’s

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