Kondamodi S. Rao and B. Satyaveni Rao - Page 12

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               Physicians and a dentist working at the medical center paid            
          rent to Dr. Rao either every time they came in for a session, or            
          on a monthly basis.  The medical center is still available for              
          rental to physicians.  Petitioner rented the upstairs portion to            
          the Forest Park Senior Citizens Center since May of 1986.4                  
               In order to calculate the medical center's expenses, as                
          reported on Schedule E, Mr. Raclaw conferred with Dr. Rao to                
          determine his monthly expenses for medical supplies, utilities,             
          paper goods, other supplies, and payments to an assistant who               
          worked there.                                                               
               Petitioners reported the medical center's gross income and             
          deductions and claimed the following losses on Schedules E for              
          the years in issue:                                                         
                             1986              1987        1988                       
               Rents received     $45,000    $46,800     $104,550                     
               Expenses:                                                              
               Advertising     950    ---     ---                                     
               Auto & travel      600        240         ---                          
               Cleaning & maint.   1,100     2,400       3,750                        
               Insurance          2,628      2,782       3,175                        
               Mortgage interest  59,719     16,182      58,196                       
               Repairs            7,558    3,100         9,202                        
               Supplies           3,600      2,000       2,186                        
               Taxes              6,698      6,811       12,191                       
               Utilities          5,951      6,000       5,510                        
               Telephone          1,118      1,263       2,489                        
               Office expense     2,370      4,185       2,680                        
               Salary             12,000     12,000      12,000                       
               Water              422        512         1,580                        


               4  This lease was entered into through Dr. Rao's                       
          corporation, Kondamudi.                                                     




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