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1995 were the total amounts of real property taxes and utilities
paid with respect to petitioner’s residence.
The joint returns for 1991 through 1995 claimed net operat-
ing loss deductions in the respective amounts of $68,739,
$75,593, $48,533, $57,136, and $40,343 with respect to claimed
net operating loss carryovers from prior years.
Petitioner and Ms. Treadaway did not report in the 1994
joint return the $3,000 that Ms. Treadaway received from the sale
of the Brenda property on May 5, 1994.
Petitioner and Ms. Treadaway did not report as income in the
1994 and 1995 joint returns any of the Social Security benefits
that they received during those years.
Respondent issued the notice with respect to 1994 and 1995
to petitioner and Anna P. Treadaway, deceased.4 In that notice,
respondent disallowed the deductions claimed for legal expenses
in Schedules C of the 1994 and 1995 joint returns because it was
not established that those claimed expenses (1) were expended,
(2) were expended for the purposes stated in those schedules, and
(3) constitute ordinary and necessary business expenses.
Respondent further disallowed in the notice the deductions
claimed for expenses in Schedules F of the 1994 and 1995 joint
returns because it was not established that those claimed ex-
penses (1) were expended, (2) were expended for the purposes
4Ms. Treadaway’s first name was Anne, not Anna.
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