Bernard L. Nadeau, Jr. and Nancy L. Nadeau - Page 4

                                                  4                                                    
                  In 1992, petitioners sold the Eden Prairie property.                                 
            Petitioners recognized a loss on the sale in the amount of                                 
            $5,806.85.  At the end of 1992, petitioners still owned the other                          
            two properties.                                                                            
                  On their 1990, 1991, and 1992 Federal income tax returns,                            
            petitioners included the gross rental receipts from real estate                            
            and the related deductions on petitioner's Schedule C, as profit                           
            or loss from petitioner's business, Nadeau Rentals.  Petitioner                            
            reduced his self-employment income by the loss from Nadeau                                 
            Rentals for each of these years.  In all of the years in issue,                            
            petitioners claimed depreciation deductions for the properties as                          
            residential real estate.  Petitioners' Federal tax return for                              
            1990 reflects the sale of the Pillsbury property as the sale of a                          
            personal residence and the sale of business property.                                      
            Petitioners recognized the portion of the gain attributable to                             
            the sale of the business property, all of which represented                                
            recapture of depreciation.                                                                 
                  Petitioners' 1991 Federal income tax return was due on or                            
            before April 15, 1992.  Petitioners received an automatic                                  
            extension of time for filing that return until August 15, 1992,                            
            and filed on September 21, 1992.  Petitioners' 1992 Federal                                
            income tax return was due on or before April 15, 1993.                                     
            Petitioners were granted extensions of time for filing that                                
            return until October 15, 1993, and filed it on February 24, 1994.                          






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