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and also claimed a dependency exemption for James, whom
petitioner identified as his infant son. Petitioner attached
Schedule A to his return. Included among the deductions claimed
on Schedule A were the following:
Real estate taxes $1,963
Home mortgage interest 2,920
Charitable contributions:
contributions by cash or check $200
other than by cash or check 400 600
Petitioner also attached Schedule E (Supplemental Income and
Loss) to his 1994 return and reported rents received (in the
amount of $3,375) and expenses with respect to the Duplex.
Petitioner underreported rents received by $2,025. Among the
deductions claimed on Schedule E were the following:
Cleaning & maintenance $1,090
Mortgage interest 1,460
Repairs 2,300
Taxes 981
Utilities 800
Petitioner duplicated deductions for (home) mortgage
interest and (real estate) taxes claimed on his Schedule A and
Schedule E for 1994. In this regard, during 1994 petitioner paid
mortgage interest in the total amount of $2,920 and real estate
taxes in the total amount of $1,963. Petitioner deducted each of
those amounts in its entirety as an itemized deduction on
Schedule A and one-half of each of those amounts as a rental
expense on Schedule E.
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