James A. Petrie IV - Page 6

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          W-2 income, and excluded the Arizona rental property income.                
                    The notice of deficiency, based on petitioner's 1990              
          joint Federal return, changed petitioner's filing status to                 
          married filing separately, disallowed the exemption for Ms.                 
          Petrie, reduced petitioner's rental income by $2,750,7 and                  
          disallowed $2,629 of petitioner's rental expenses.                          
               For 1991, petitioner initially timely filed a joint Federal            
          return and claimed exemptions for himself and Ms. Petrie and                
          three dependency exemptions.  The 1991 joint Federal return                 
          reported petitioner's W-2 income, petitioner's AT&T retirement              
          income, 100 percent of the income from the Arizona rental                   
          property in the amount of $6,000, and Arizona rental property               
          expenses of $4,608.8                                                        
               Petitioner amended his 1991 joint Federal return in which he           
          claimed head of household filing status, omitted the exemption              
          amount for Ms. Petrie, and excluded the Arizona rental property             
          income.                                                                     



          7         One-half of $5,500, the amount reported by petitioner on the 1990 
          joint Federal return.                                                       
          8         The 1991 rental expenses reported by petitioner on the joint      
          Federal return were as follows:                                             
                    Auto and travel          $300                                     
                    Cleaning and maintenance      200                                 
                    Insurance                     325                                 
                    Mortgage interest          1,530                                  
                    Repairs                  250                                      
                    Taxes          790                                                
                    Depreciation                1,213                                 
                         Total           4,608                                        




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