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petitioners’ document to establish petitioners’ respective
positions on the various issues that remain in these cases.
Claimed Rental Income for 1996
Petitioners contend that they have rental income for 1996
from the Warren Avenue rental property of $88,744.73, and not
$108,000 as determined by respondent. On the record before us,
we reject petitioners’ contention. We find on that record that
petitioners have failed to carry their burden of showing that
during 1996 they received only $88,744.73 of rental income from
the Warren Avenue rental property.4
Claimed Rental Deductions for 1996
Petitioners contend that they are entitled to deduct for
1996 rental expenses totaling $98,103.07. On the record before
us, we reject petitioners’ contention. We find on that record
that petitioners have failed to carry their burden of showing
that they are entitled to deduct for 1996 a total of $98,103.07
as rental expenses.
Other Deductions Claimed for the Years at Issue
Petitioners contend that they are entitled to deduct for
each of the years at issue the following amounts which they
3(...continued)
tures incurred by those attorneys.
4We note that, pursuant to Rule 90(c), petitioners are
deemed to have admitted that during 1996 they received $108,000
of rental income from the Warren Avenue rental property.
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