William Barry Blythe and Cheryl Lynn Blythe - Page 3




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          ing seven parcels until the lenders foreclosed on them during               
          1995.  Mr. Blythe acquired and held title to the ten parcels in             
          question for the purpose of producing rental income from such               
          parcels.  He did not acquire and hold title to those parcels for            
          the purpose of selling them with a view to the gains and profits            
          that might be derived from such sales.                                      
               Throughout the various periods during which Mr. Blythe held            
          title to the ten parcels, the respective occupants of those                 
          parcels made rental payments to petitioners.  Throughout those              
          periods, petitioners did not pay any property taxes or make any             
          mortgage loan payments with respect to any of those parcels.  Nor           
          did Mr. Blythe offer or advertise any of them for sale.                     
               In Schedule C of their return for 1994 (1994 Schedule C),              
          petitioners reported the rental payments that they received                 
          during that year from the ten parcels in question as gross                  
          receipts from a business which they described as "Property Mgmt".           
          Petitioners reported no other gross receipts or income in their             
          1994 return.  Petitioners claimed in their 1994 Schedule C total            
          expenses of $54,372.2  Those expenses did not include any claimed           
          depreciation.  Petitioners reported in their 1994 Schedule C a              
          net profit of $5,229.  Each of them reported in a separate                  
          Schedule SE, Self-Employment Tax, of their 1994 return (1994                
          Schedule SE) about one-half (viz. $2,615) of that claimed 1994              
          Schedule C net profit and "Net earnings from self-employment" of            

               2  In fact, the various expenses that petitioners claimed in           
          their 1994 Schedule C total $54,880, not $54,372.                           

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