John Charles Treadaway, Sr. - Page 9




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          stated in those schedules, and (3) constitute ordinary and                  
          necessary business expenses.  Respondent determined in the                  
          alternative that the deductions claimed in Schedules F of the               
          1994 and 1995 joint returns were for expenses incurred in an                
          activity not entered into for profit and increased the taxable              
          income reported in those returns by the respective losses of                
          $32,855 and $15,326 claimed in those schedules (i.e., by the                
          excess of the deductions claimed over the income reported in each           
          such schedule).                                                             
               Respondent further disallowed in the notice the net operat-            
          ing loss deductions claimed in the 1994 and 1995 joint returns.             
               Respondent also determined in the notice that the joint                
          return for 1994 improperly did not report the $3,000 that Ms.               
          Treadaway received in that year from the sale of the Brenda                 
          property, that no basis in excess of zero in that property was              
          established, and that that amount is capital gain.                          
               Respondent further determined in the notice that, because of           
          other determinations therein, 85 percent of the respective                  
          amounts of Social Security benefits that petitioner and Ms.                 
          Treadaway received during 1994 and 1995 are includible in taxable           
          income for those years.                                                     
               Respondent also determined in the notice that all of the               
          underpayment of tax for 1994 and 1995, as determined therein, was           
          due to negligence or disregard of rules or regulations and                  






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