Joellen Miller Murata - Page 7

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            project.  Mr. Miller conveyed the unfinished house and property                            
            (collectively, the New Bremen property) to petitioner by deed                              
            dated February 23, 1989.  On February 23, 1989, petitioner signed                          
            a building loan and agreement (the mortgage) with the St.                                  
            Lawrence National Bank (the bank) in which the bank agreed to                              
            lend petitioner $44,000, which was to be used for the                                      
            construction and completion of the unfinished house.  These                                
            improvements included the completion of a cellar, septic tank,                             
            exterior framing, and interior finish work and the installation                            
            of external siding, electricity, and plumbing.  According to                               
            petitioner, she used the loan proceeds of $44,000 to purchase the                          
            New Bremen property from Mr. Miller.  The record contains no                               
            indication as to the cost of the land or the finished house.                               
                  Mr. Miller used the $44,000 to complete construction of the                          
            unfinished house.  After the completion of the house, Mr. Miller                           
            resided in it with his family and faithfully made all required                             
            payments with respect thereto; i.e., mortgage, taxes, repairs.                             
            Petitioner included $3,416.92 in her gross income, which she                               
            described as related to the mortgage payments made by Mr. Miller.                          
                  On Schedule A of their joint Federal income tax return,                              
            petitioner and Mr. Ganong claimed a deduction for job expenses                             
            and other miscellaneous expenses of $12,195.49.  Of this amount,                           
            $4,125 related to research expenses; $1,274.80 related to                                  
            petitioner's job search expenses; $3,378 related to Mr. Ganong's                           





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