- 4 - from the rental of another property listed as Jefferson Manor Apartments. They reported carryover passive losses of $23,106 and $45,830 for 1993 and 1994, respectively. Petitioners used $10,490 and $15,906 of the passive losses to offset the Rochester Street building rent and reduced the amounts of rent to the amounts of $13 and $31 for 1993 and 1994, respectively. Petitioners further reduced the amounts of rent to $0 for both years after deduction of passive losses from a partnership listed as Dodge Corners Inv. Cl. in the amounts of $13 and $31 for 1993 and 1994, respectively. Thus, petitioners used total passive losses of $10,503 ($10,490 + $13) and $15,937 ($15,906 + $31) to offset the rental incomes from the Rochester Street building for 1993 and 1994, respectively. Respondent determined that the rental profits from the Rochester Street building are nonpassive income and therefore were not allowable to offset petitioners' passive losses. As respondent stated in the notice of deficiency: On Schedule E of your 1993 AND [sic] 1994 returns, you reported net profits from your rental properties in the amounts of $10,503 in 1993 and $15,937 in 1994. You treated these profits as passive income which you than [sic] used to offset passive losses. It has been determined that these rental net profits are nonpassive income and therefore unallowable to offset your passive losses. Therefore, your taxable incomes for 1993 and 1994 are increased by $10,503 and $15,937, respectively. Respondent also adjusted petitioners' itemized deductions for both years, child care credit for 1993, and the exemptionsPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011