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either 1993 or 1994. Petitioner was aware that the withdrawals
from her qualified IRA’s would be taxable to her, but she
withdrew the money in order to subsist and to help her family.
For the 1993 taxable year, Transworld Mortgage Corp. issued
petitioner and her sister, Adrianna, a Form 1098 Mortgage
Interest Statement reporting the payment of $8,189.68 in
deductible mortgage interest. For the 1994 taxable year,
Transworld Mortgage Corp. issued petitioner and Adrianna a Form
1098 Mortgage Interest Statement reporting the payment of
$7,386.58 in deductible mortgage interest.
After the trial, the record remained open to give petitioner
an opportunity to submit additional evidence in order to
substantiate certain additional Schedule A itemized deductions.
Petitioner submitted documentation regarding medical expenses,
real property taxes, automobile fees, corporate organizational
expenses, and interest expenses. Specifically, in 1993 and 1994,
various doctors were paid $1,501.74 and $631.14, respectively,
from a joint checking account that petitioner maintained with her
mother and her sister. Petitioner paid $1,866.81 and $1,910.13
in 1993 and 1994, respectively, in real property taxes. In 1993
and 1994, respectively, payments of $379.95 and $236.95 were made
to the California Department of Motor Vehicles (DMV) for
registration fees and smog certification fees. Petitioner also
paid the California DMV $93 in 1994 for an automobile sales
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