5
The bankruptcy court discharged petitioner's chapter 11
bankruptcy in 1991. The bankruptcy estate did not file a tax
return for 1991.
D. The Estates of Petitioner's Mother and Aunt and Petitioner's
Management of His Sons' Real Property
Petitioner wrote wills for his mother, who died in 1987, and
his aunt, who died in 1988. Their estates totaled about $1
million. One-half of that amount passed to petitioner's sister.
The other one-half passed to petitioner's two sons because
petitioner did not want more assets while his bankruptcy case was
pending.
Petitioner's two sons were around ages 15 and 16 in 1988.
Petitioner bought and managed real property in Texas and Oklahoma
with their $500,000 share of the inheritance. He charged his
sons $2,500 to $3,500 per month to manage the property.
Petitioner reported income from trustee's fees of $33,000 for
1991 and $30,000 for 1992.
E. Petitioner's Real Property
In 1991 and 1992, petitioner owned rental real property for
which he claimed expenses. He owned the Centre City Hotel in San
Diego, California, the Riviera Apartments in San Diego, a
condominium in Marina del Rey, California, the Schaefer Hotel in
Baltimore, Maryland, and the Brentwood Apartments in Baltimore.
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