- 2 - of $290 in petitioners' 1991 Federal income tax. On the basis of petitioners' amended return, as well as arguments at trial, it is clear that petitioners claim an overpayment in the amount of $461. After concessions,2 the issues for decision are: (1) The characterization of income and expenses relating to petitioner Guido Ruggiero's (petitioner) activities during the taxable year 1991 and (2) the characterization of expenses incurred by petitioners in renting out their house during part of the year in issue. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. At the time of filing the petition, petitioner resided at Coral Gables, Florida, and petitioner Kristin Ruggiero resided at Cambridge, Massachusetts. 1(...continued) Tax Court Rules of Practice and Procedure. 2 Petitioners have conceded they are not entitled to deduct travel expenses claimed in the amount of $3,732, and they are not entitled to deduct claimed Schedule E expenses for repairs and maintenance in the amount of $318 and depreciation in the amount of $2,824, attributable to the rental use of their Connecticut house. The parties further agree that net royalty income in the amount of $236, received by petitioner Kristin Ruggiero, should have been reported on Schedule E, rather than on Schedule C.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011