John M. Schaefer - Page 7

                                          7                                           
                                        1991                                          
                              Amount         Amount         Amount                    
           Rental property     deducted       allowed       disallowed                
          Centre City Hotel   $71,396        $51,032        $20,364                   
          Riviera Apts.       143,595        51,545         92,050                    
          Schaefer Hotel      32,238         15,771         16,467                    
          Brentwood Apts.      6,000          --             6,000                    
                              253,229        118,348        134,881                   

                                        1992                                          
                              Amount         Amount         Amount                    
           Rental property     deducted       allowed       disallowed                
          Centre City Hotel   $52,662        $21,405        $31,257                   
          Riviera Apts.       99,487         33,960         65,527                    
          Schaefer Hotel      11,107         --             11,107                    
          Marina del Rey condo    9,600       --             9,600                    
                              172,856        55,365         117,491                   
               Petitioner also deducted an additional $70,198 of                      
          unspecified Schedule E expenses for the Centre City Hotel for               
          1992, based on his estimate that his expenses were about 50                 
          percent of the monthly revenues from the hotel.  The $70,198                
          estimate did not include amounts petitioner deducted for real               
          estate taxes, interest, petty cash and miscellaneous expenses,              
          fire insurance, fire sprinklers, and depreciation.                          
               Petitioner deducted Schedule C expenses for 1991 and 1992.             
          Respondent determined that petitioner's deductions should be                
          reduced as follows:                                                         










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