Lucila Novoa - Page 4

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               On her 1993 income tax return, petitioner claimed the                  
          standard deduction and reported gross receipts and expenses of              
          her trucking business on Schedule C in the following amounts:               
                    Gross receipts                $44,275                             
                    Expenses                                                          
                         Tolls                         2,900                          
                         Depreciation                  3,000                          
                         Insurance                     1,300                          
                         Repairs & maintenance         1,600                          
                         Supplies                      1,335                          
                         Taxes (registration)          919                            
                         Wages                         3,000                          
                         Other expenses (fuel,                                        
                        tires, parking, road tax)    14,260                          
                         Total expenses           28,314                              
                    Net business income           15,961                              

               At an unspecified time in 1993, petitioner sold one of her             
          trucks for $12,000.  In July 1991, petitioner had purchased                 
          the truck for $14,000 and had paid $500 for a truck warranty.               
          Petitioner had claimed depreciation deductions on the truck of              
          $1,450 and $2,900 for the 1991 and 1992 taxable years,                      
          respectively.  Petitioner did not report the sale of the truck on           
          her 1993 tax return.                                                        
          B.   Rental Activity                                                        
               During 1993, petitioner purchased a two-family house in                
          North Bergen, New Jersey, and on April 1, 1993, she moved into              
          the house.  Petitioner paid the purchase price of $170,000 for              
          the house in the following manner:                                          
               Initial deposit on purchase             $22,500                        
               Payment at closing of title             22,500                         
               Mortgage loan proceeds                  125,000                        
                    Purchase price                     170,000                        



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