Jerome J. and Beatrice A. Mack - Page 11

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          payment of two mortgage notes secured by the Third Street                   
          property and the additional note executed by petitioner and Mr.             
          Moosbrugger individually and secured by their guarantees.                   
               On Schedule E, Supplemental Income Schedule, attached to               
          petitioners' 1979 Federal income tax return, petitioners reported           
          rental income in the amount of $7,114 and deducted expenses of              
          $6,020.69 for interest and $4,331.80 for depreciation related to            
          the Third Street property.  The interest and depreciation                   
          expenses claimed were indicated to be 50 percent of the total               
          expenses on the building.                                                   
               A depreciation schedule attached to petitioners' 1987                  
          Federal income tax return reflects that petitioners reported a              
          one-half interest in the Third Street property and all                      
          improvements.                                                               
               On Schedule E, Supplemental Income Schedule, of petitioners'           
          Federal income tax returns for the years 1986 and 1987, they                
          reported the following amounts in connection with the Third                 
          Street property:                                                            
               Item                           1986           1987                     
               Rents received                $7,425         $7,425                    
               Expenses:                                                              
                         Interest            6,542          6,542                     
                         Taxes               2,173          2,173                     
                         Depreciation        1,200          1,200                     

          The rental income reported by petitioners for the taxable years             
          1986 and 1987 was 50 percent of the total rental income.                    






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