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return.
Petitioner’s returns for 1979, 1987 through 1989, and 1991
through 1993 included Schedules B, Interest and Dividend Income,
showing taxable interest income and, for certain of those years,
dividend income. Petitioner’s returns for 1979 and 1991 through
1993 included Schedules C, each of which showed net profit or a
loss from a business other than a business of making loans or any
other type of investment business.5 Petitioner’s returns for
1979, 1987, 1988, and 1991 through 1993 included Schedules D,
certain of which showed a net capital gain and others of which
showed a net capital loss.6 Petitioner’s returns for 1979, 1987,
1989, and 1991 through 1993 included Schedules E which showed
(1) income or a loss from two or more rental properties,7 (2) for
5Petitioner’s 1979 return included four Schedules C, each of
which showed net profit or a loss from a business. Petitioner’s
1991 return included two Schedules C, each of which showed a loss
from a business. Each of petitioner’s returns for 1992 and 1993
included one Schedule C, each of which showed a loss from a
business.
6In Schedule D of each of petitioner’s returns for 1991 and
1992, petitioner reported a net capital loss which was attribut-
able to a claimed nonbusiness bad debt.
7The following chart shows the number of rental properties
from which petitioner reported rents received in Schedule E of
each of his returns for 1979, 1987, 1989, and 1991 through 1993:
(continued...)
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