Douglas Ritter - Page 5

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          101 Robinson Street properties, respectively, is includable in              
          petitioner's income for 1991.  We further hold that the remaining           
          rental income of $10,732.70 reported on the Form 1099-MISC, as              
          well as the $5 of interest income, is includable in petitioner's            
          income for 1991.  In short, petitioner failed to report                     
          $18,680.70 of income for 1991.                                              
          Rental Expenses                                                             
               Petitioner contends he has incurred rental expenses with               
          respect to the properties that he should be able to deduct                  
          against the income he received.  Petitioner submitted the                   
          following list at trial:                                                    
               53 Mary St.                                                            
                    utilities       $2293.55                                          
                    taxes           $3341.58                                          
               99-101 Robinson St.                                                    
                    utilities       $2617.28                                          
                    taxes           $3713.20                                          
               18 Pleasant Ave.                                                       
                    taxes           $1067.34                                          
               RD2-Conklin prop.                                                      
                    taxes            $576.17                                          
                    trash removal    $644.16                                          
               41 Charlotte St.                                                       
                    taxes           $1494.73                                          
               Church Road                                                            
                    taxes            $429.17                                          
               Langdon Grove                                                          
                    taxes           $1294.16                                          
                    trash removal   $1043.95                                          
               Taxpayers do not have an inherent right to take tax                    
          deductions.  Deductions are a matter of legislative grace, and              
          taxpayers must establish their right to take them.  Deputy v. du            
          Pont, 308 U.S. 488, 493 (1940); New Colonial Ice Co. v.                     





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