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Law of Federal Income Taxation, sec. 15.05, at 21, 15.22, at 57
(1997 rev.).
Although petitioners object to this adjustment to the
partnership’s income for 1991, petitioners provide no basis for
their objection. We sustain respondent’s adjustment.
Rental Income
During the years in issue, petitioners owned a number of
rental properties on which they received rental income.
Petitioners reported on their 1990 joint Federal income tax
return $29,550 in rental income relating to these properties.
Respondent determined that in 1990 petitioners received
$31,441 of rental income from these rental properties and that
petitioners failed to report $1,891 of such rental income.
Under section 61(a)(5), funds received from rental of
property are included in a taxpayer’s income.
Although petitioners dispute respondent’s adjustment,
petitioners provided no testimony or evidence to disprove the
adjustment. We sustain this adjustment.
Depreciation of Videos
As indicated, during the years in issue, videos were
purchased by the partnership and by petitioner for rental to
customers.
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