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schedule, they reported “Rents received” of $34,958 and claimed
“Total expenses” of $62,884 and a “Deductible rental loss” of
$8,378 with respect to the Sanchez Street property. In Part I of
the 1991 Schedule E, petitioner and Ms. Brodsky claimed “Total
rental or royalty income or (loss)” of ($10,493) with respect to
the Church Street property and the Sanchez Street property.
On page 1 of the 1992 joint return, petitioner and Ms.
Brodsky reported, inter alia, the following:
Line on Page 1 of
Item of Income or (Loss) the 1992 Return Amount
Wages, salaries, tips, etc. 7 $65,805
Taxable interest income 8a 459
Dividend income 9 856
Taxable refunds, credits, or off- 10 1,626
sets of state and local income taxes
Business income or (loss) 12 5,951
Capital gain or (loss) 13 (3,000)
Total pensions and annuities 17a 19,157
Rents, royalties, partnerships, 18 (3,167)
estates, trusts, etc.
Other income2 22 (883)
1Petitioner and Ms. Brodsky reported on page 1, line 17b, that only $354
of the reported amount of pensions and annuities was taxable.
2Petitioner and Ms. Brodsky described their “Other income” as an
“INVESTMENT INTEREST CARRYOVER”.
The 1992 joint return showed “adjusted gross income” of $67,580,
“Itemized deductions” of $84,921, and no “Taxable income”.
The 1992 joint return included Schedule C which indicated
that petitioner operated an audio-video sales business under the
name Zinovy Brodsky. In Part I, Income, of the 1992 Schedule C,
petitioner and Ms. Brodsky reported “Gross receipts or sales” of
$293,937, “Cost of goods sold” of $258,180, and “Gross income” of
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