- 15 - penalty under section 6663. Petitioners' reply denied receipt of the $150,000. The parties have since stipulated that petitioners omitted only the following items of income from their Schedules C attached to their 1990 return: (1) The consultation fee of $150,000 paid to Susanna d.b.a. Sand Hill on March 20, 1990, by Meiyan; and (2) the sum of $840,000 paid to petitioners on October 30, 1990, by Sanrio. The parties agree that section 6662(a) applies to the deficiency attributable to the unreported income to the extent that the Court concludes that section 6663 is inapplicable. II. The Mortgage Interest Deduction Until 1989, petitioners owned a condominium in San Mateo, California, that they used as their primary residence. In 1989, after their move, petitioners subsequently reclassified the condominium as rental property. In that year, petitioners also purchased a home in Hillsborough, California, for use as their primary residence and they have since lived there at all times. The purchase price of the residence was $1,780,000. Petitioners have a mortgage on the Hillsborough residence, the original principal amount of which was $1,330,000. In 1990, petitioners claimed a home mortgage interest deduction on Schedule A of $107,226. Despite having actually paid a greater amount of mortgage interest, petitioners limitedPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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