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Eric, petitioner’s grandson, moved in with petitioner in the
latter half of 1996. Eric’s parents paid for all of Eric’s
clothing. Petitioner paid for Eric’s food and gave Eric
presents.
Petitioner did not file a Federal income tax return for
1993.
Petitioner filed his 1995 return on June 29, 1998.
Petitioner deducted $4,135 for investment interest and $6,129 for
other expenses on Schedule A, Itemized Deductions. Petitioner
also reported on Schedule E, Supplemental Income and Loss, a loss
of $10,202 related to the house in the Bahamas.
Petitioner filed his 1996 return claiming head-of-household
filing status on August 3, 1998. Petitioner reported a loss of
$10,758 on Schedule E related to the house in the Bahamas.
Petitioner timely filed his 1997 return. Petitioner
reported a loss of $10,333 on Schedule E related to the house in
the Bahamas.
Respondent mailed a notice of deficiency to petitioner on
January 7, 2000, for tax years 1993, 1996, and 1997, and a
separate notice on the same day for tax year 1995. Respondent
determined that petitioner failed to report interest income from
the tax certificates of $49,805, $19,249, $14,656, and $6,603 for
1993, 1995, 1996, and 1997, respectively. Respondent asserts
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