- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011