- 4 -
exceeded $75,000. They continued to own the property when they
moved to the United States. In September 1988, petitioners sold
the house for $75,000 plus interest to Andres Rivera Rodriguez
(Mr. Rodriguez), who paid them $25,000 in principal and $18,000
in interest in 1991 and $50,000 in principal and $4,000 in
interest in 1992. Petitioners received the $25,000 in 1991 in
four cash payments, which were deposited in the business bank
account at Osceola National. The exact amount of $50,000 was
deposited on October 13, 1992, in Mr. Ortiz' business bank
account. Some of the interest payments received from Mr.
Rodriguez, $3,500 in 1991 and $3,000 in 1992, were by checks
which were deposited in petitioners' personal bank account. The
remainder of the payments received in 1991 and 1992 was
apparently received in cash.
Mrs. Ortiz
In 1991 and 1992, Mrs. Ortiz worked as a pharmacist for Rite
Aid and GM Drug Company. She received wages of $19,291 in 1991
and $12,938 in 1992. The Federal income tax withheld was $1,560
in 1991 and $1,029 in 1992. The checks she received from these
employers were deposited in petitioners' personal bank account.
The amounts received by Mrs. Ortiz were reported by her as gross
income on petitioners' Federal income tax returns for 1991 and
1992. She also received de minimis amounts from Como Pharmacy
that were not reported and not determined by respondent to be
self-employment income.
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