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Zinovy Brodsky. In Part I, Income, of the 1991 Schedule C,
petitioner and Ms. Brodsky reported “Gross receipts or sales” of
$380,364, “Cost of goods sold” of $317,429, “Other income” of
$700, and “gross income” of $63,635. In Part II of the 1991
Schedule C, Expenses, petitioner and Ms. Brodsky claimed deduc-
tions for, inter alia, “Other Interest” of $3,000 and “Other
expenses” of $3,877.9 Petitioner and Ms. Brodsky reported in the
1991 Schedule C “total expenses before expenses for business use
of your home” of $33,183, “Expenses for business use of your
home” of $9,641, and “Net profit or (loss)” of $20,811.
The 1991 joint return also included Schedule E, Supplemental
Income and Loss (Schedule E), in which petitioner and Ms. Brodsky
reported the Church Street property and the Sanchez Street
property as rental properties. In Part I of the 1991 Schedule E,
petitioner and Ms. Brodsky claimed only “Rental and Royalty
Expenses” with respect to the Church Street property and both
“Rental and Royalty Income” and “Rental and Royalty Expenses”
with respect to the Sanchez Street property. In Part I of the
1991 Schedule E, petitioner and Ms. Brodsky claimed “Total
expenses” of $8,461 and a “Deductible rental loss” of $2,115 with
respect to the Church Street property. In that part of that
9According to a statement attached to their 1991 joint
return, petitioner and Ms. Brodsky reported that the deduction
claimed for “Other expenses” included, inter alia, $1,058 for
“CAR PHONE” and $1,445 for “PHONE”.
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