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Other Rental Deductions
Respondent has proposed as a finding of fact that
petitioners are entitled to deductions for rental property
expenses and mileage in the following aggregated amounts:
Year Amount
1982 $7,528.00
1983 2,072.92
1984 2,234.76
1985 4,887.57
1986 562.15
1987 7,256.86
We find accordingly. Petitioners have failed to prove that they
incurred any additional rental property expenses or mileage. No
further deduction for rental property expenses or mileage is
allowed.
Additions to Tax
1. Failure to File
Respondent determined section 6651(a)(1) additions to tax
against Walter for his 1982 through 1986 taxable years. Section
6651(a)(1) provides that, in the case of a failure to file an
income tax return by the due date, there shall be imposed an
addition to tax for such failure of 5 percent of the amount of
tax, reduced by timely payments and credits under section
6651(b)(1), for each month or portion thereof during which the
failure continues, not exceeding 25 percent in the aggregate,
unless such failure is due to reasonable cause and not due to
willful neglect.
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