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Petitioner and Mrs. Condello have two children. Under the
divorce decree issued in 1994, petitioner and Mrs. Condello were
given joint custody of the children. During 1992, however, the
children resided with Mrs. Condello.
For the 1992 taxable year, petitioner and Mrs. Condello
filed separate Federal income tax returns. Petitioner filed his
1992 Federal income tax return (the return) in or around October
1995. On the return, petitioner reported 100 percent of his
C.P.A. business income and only one-half of his other income. He
also reported approximately one-half of Mrs. Condello's 1992
income on the return.
On the return, petitioner also claimed numerous deductions
that respondent denied. On his Schedule A, petitioner deducted
$8,500 for legal fees relating to his divorce proceeding.
Petitioner also deducted on Schedule A one-half of the total
mortgage interest and real property taxes paid on a house located
at 5012 Bridgewater Drive (the Bridgewater house). Mrs. Condello
paid the mortgage and real property taxes on the Bridgewater
house with rental income from her separate property. On his
Schedule C for his C.P.A. business, petitioner claimed deductions
in the amount of $12,478 relating to that business. On his
Schedule E, petitioner claimed deductions relating to a rental
property located at 5900 Oregon Trail Court (the rental property)
and reported a loss of $2,132.
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