- 6 -
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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