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private lock on his or her bedroom door. Two tenants had access
to a single parking space in the garage.
During 1991, except for the 1-month period that he was in
China, petitioner used the San Bruno residence as his principal
residence, reserving the master bedroom and a parking space in
the garage for his exclusive use.
In late 1991, petitioner was offered a teaching job, which
he accepted, at Petroleum University in Beijing, China, for the
1992 academic year. Petitioner moved to China in September 1992
to begin teaching and has made no personal use of the San Bruno
residence since that time.
On a Schedule E filed with his 1991 Federal income tax
return, petitioner reported the following items attributable to
the rental use of the San Bruno residence:
Income: $4,815.00
Expenses:
Advertising $856.27
Auto & travel 647.24
Cleaning & maintenance 1,423.18
Insurance 818.42
Mortgage interest 10,283.90
Repairs 202.25
Taxes 1,571.12
Utilities 1,184.88
Lamp, telephone 230.92
Dry rot repair 298.00
Depreciation 9,893.28 27,409.46
Net loss: 22,594.46
With the exception of the depreciation deduction, and
assuming, without finding, that petitioner properly allocated the
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