Alonzo and Emma J. Bradley - Page 6

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          total mileage for that year (12,867 miles and 1,176 miles,                  
          respectively).  Petitioners claimed an additional $677 in                   
          miscellaneous business expenses in connection with Mrs. Bradley's           
          employment for a total of $5,777 in unreimbursed employee                   
          business expenses.                                                          
               In the notice of deficiency, respondent disallowed claimed             
          deductions for all of petitioners' employee business expenses on            
          the grounds that (i) they constituted reimbursable transportation           
          expenses and/or (ii) they constituted personal commuting                    
          expenses.                                                                   
               On Schedule E of their return, petitioners claimed $22,507             
          in losses with respect to four pieces of real property held by              
          them in 1992, consisting of three residential rental properties             
          (the Hearthwood Condominium, the River Stone II Condominium, and            
          a house in Windsor Village) and a parcel of vacant land in Utica,           
          Mississippi (the Mississippi land).  Petitioners computed losses            
          on Schedule E as follows:                                                   
                                        Windsor    Mississippi                        
          Item             Hearthwood  River Stone   Village       Land       Total   
          Income (Rents) $2,400    $3,000    $2,400       -0-         $7,800          
          Expenses (Management                                                        
          fees, mortgage                                                              
          interest, etc.)       6,472     8,8864,743      $2,003       22,104           
          Depreciation       2,757     3,628   1,818     -0-         8,203            
          Loss           ($6,829)   ($9,514)    ($4,161)    ($2,003)    ($22,507)     

               In the notice of deficiency, respondent disallowed the                 
          $22,104 in expenses claimed by petitioners with respect to the              





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