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received a payment of $30,000 in discharge of the remaining
obligation under the $120,000 note.
At the time of trial, petitioner still owned three of the
California rental properties. During 1992 and 1993, two of those
properties rented for between $675 and $750 a month and one
rented for between $525 and $550 a month. Petitioner sold the
fourth California rental property in October 1992, receiving a
note in the principal amount of $110,000, calling for monthly
payments of $945. Prior to its sale, the fourth California
property rented for between $575 and $625 a month. Most of the
rental payments petitioner received with respect to the
California properties were received in cash, collected by her or
her son, Gary. When Gary collected the rental payments, he
deposited them in a bank account petitioner maintained in
California, and she would write checks on that account.
Petitioner relied on her memory to report her rental receipts to
her accountant (who prepared her Federal income tax return).
In April 1990, petitioner purchased a two-bedroom
condominium apartment in Las Vegas, Nevada (the Las Vegas
property), for $145,000, in cash. She obtained that sum from the
proceeds of the sale of the Dunedin property and a loan of
$110,000 from NCNB National Bank. The Las Vegas property was
held for rental, for between $800 and $1,100 a month.
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