Chester F. and Faye L. Sidell - Page 7




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          Request for Certification of Completed Work" to the Park Service.           
          Rehabilitation costs totaling $1,701,988 in 1993 and $84,435 in             
          1994 were incurred with regard to the rehabilitated Kunhardt Mill           
          property.1  An additional $200,000 was incurred in related costs            
          associated with obtaining "qualified rehabilitation" status.                
          Petitioners' 1993 and 1994 Federal Income Tax Returns                       
               Petitioners timely filed their 1993 and 1994 Federal income            
          tax returns.  On their returns, petitioners reported the following          
          net rental income:                                                          
          Property                      Net Rental Income/(Loss)                      
          1993       1994                                                             
          Manche/Everett Mill property          $122,139    $45,936                   
          CFS/Kunhardt Mill property             138,451     (5,335)                  
          FLS property                           (42,758)    57,894                   
          GES property                            (2,272)   (25,315)                  
          RMS property                             N/A      (11,855)                  
          Rental activities with net income      260,590    103,830                   
          Rental activities with net loss        (45,030)   (42,505)                  
          Net rental income                      215,560     61,325                   
               Petitioners also claimed rehabilitation credits of $85,361 in          
          1993 and $24,284 in 1994 with regard to the Kunhardt Mill property          
          renovations.                                                                



               1    The record does not enable us to account for the                  
          discrepancy between the stipulated amounts of rehabilitation                
          costs for 1993 ($1,701,988) and 1994 ($84,435) and the amounts              
          reflected on petitioners' Federal tax returns for 1993                      
          ($1,734,163) and 1994 ($89,725).                                            




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