- 41 - have found as rent items constituting gross income only those amounts labeled as "Rental Income". We sustain respondent's determinations of deficiencies for 1982 through 1985 that are based on the "Additional Income" set forth on Exhibit 201-GK only to that extent. Deductions 1987 Schedule E Loss On Schedule E attached to petitioners' 1987 U.S. Individual Income Tax Return, petitioners claimed a loss from rental property (identified as "office 10245 Wilsonville, Wilson") of $1,936.02. Respondent disallowed that loss on the ground, among others, that petitioners had not established that the property was anything other than their personal residence. On brief, in objection to respondent's proposed finding of fact that petitioners claimed Walter's office in petitioners' home as a rental property, petitioners argue that the loss in question represents management expenses attributable to rental properties, but not directly attributable to a specific rental property. Petitioners have failed to carry their burden of proving that they incurred the expenses in question or that, indeed, they related to any rental properties owned by one or the other (or both) of them. Respondent's disallowance is sustained.Page: Previous 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 Next
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