Mary T. King and Fatai O. King - Page 7




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             mentioned above, petitioners reported cost of good sold of                 
             $11,809 on their amended return.  Thus, we hereby sustain                  
             that adjustment.                                                           
                  In their posttrial brief, petitioners do not take                     
             issue with respondent’s determination that their gross                     
             income should be increased by unreported interest income                   
             in the aggregate amount of $489.  At trial, petitioner                     
             acknowledged receiving interest income from accounts at                    
             three banks in the aggregate amount of $489 during 1993.                   
             Thus, we hereby sustain that adjustment.                                   
                  Finally, in their posttrial brief, petitioners do not                 
             take issue with respondent’s determination that their gross                
             income should be increased by unreported “rental income” of                
             $14,067.  As mentioned above, petitioners reported “News                   
             Stand Rental” of $14,067 on their amended return.  Even                    
             though petitioners do not take issue with this adjustment,                 
             it requires discussion.                                                    
                  At trial, petitioner acknowledged that he had received                
             $2,400 from the rental of his newsstand on Wayne Avenue and                
             had received $10,833 from the sale of his newsstand on Knox                
             Street, a deposit of $5,000 and six installment payments of                
             $972.22 each.  Petitioners do not claim that the proceeds                  
             from the sale of the newsstand on Knox Street should be                    
             reduced by any basis in the property sold.  The total of                   






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