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Respondent determined a deficiency in petitioner's 1991
Federal income tax in the amount of $3,845, and an addition to
tax under section 6651(a)(1) in the amount of $961. The Court
must decide: (1) The amount of rental income petitioner received
from the Broome County, New York, Department of Social Services
for the year 1991; (2) whether petitioner is entitled to any
deductions for rental expenses incurred; (3) whether petitioner
is entitled to three additional dependency exemptions; and
(4) whether petitioner is liable for an addition to tax under
section 6651(a)(1) for failure to timely file a tax return.
Some of the facts in the case have been stipulated and are
so found. Petitioner resided in Lisle, New York, at the time he
filed his petition.
For clarity and convenience, the findings of fact and
opinion have been combined.
In 1991, petitioner owned the following real property in
Broome County, New York:
41 Charlotte Street, Binghamton, New York
18 Pleasant Avenue, Binghamton, New York
RD 2, Box 133 and 134, Conklin, New York
In 1991, petitioner owned the following real property with
his wife, Carole Ritter, as tenants by the entireties:
53 Mary Street, Binghamton, New York
99-101 Robinson Street, Binghamton, New York
Langdon Grove, Kirkwood, New York
Church Road, Lisle, New York
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