George R. and Donelle C. Hawthorne - Page 13




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          Schedule C Income and Expenses Claimed by Petitioners                        
               Schedule C Income Claimed by Petitioners                                
               Around 1980, Mr. Hawthorne sold a motel and reported no gain            
          from that sale.  Pursuant to the terms of the real estate con-               
          tract relating to that sale, Mr. Hawthorne received $1,957.68 in             
          interest income during 1992, which petitioners reported in                   
          Schedule C of their 1992 return.  Respondent determined in the               
          notice that that interest income is Schedule B interest income               
          for 1992.  Petitioners contend that that determination is wrong.             
               On the record before us, we find that petitioners have                  
          failed to show that the interest income in question was attribut-            
          able to the carrying on of a trade or business at the time around            
          1980 when Mr. Hawthorne sold the motel or at any other time.                 
          Accordingly we sustain respondent's determination in the notice              
          that that interest income for 1992 is Schedule B interest income.            
               Schedule C Expenses Claimed by Petitioners                              
               In Schedules C of their 1992, 1993, and 1994 returns,                   
          petitioners claimed expenses totaling $13,337.59, $13,098.76, and            
          $9,981.94, respectively.  Included in the expenses claimed in                
          Schedules C for 1992 were $716.32 for "Legal and professional                
          services", $2,775.04 for "Taxes and licenses", and $3,106.06 for             
          "Depreciation".  Included in the expenses claimed in Schedules C             
          for 1993 and 1994 were $3,621.18 and $2,064.25, respectively, for            
          "Taxes and licenses" and $3,106.06 for "Depreciation".                       
               In the notice for 1992, respondent disallowed all of the                
          expenses that petitioners claimed in Schedule C of their return              


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