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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.
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