Kenneth Lee and Margaret Ihlenfeldt - Page 6




                                        - 6 -                                         
          Capital gain          -0-    16,471      -0-      -0-     -0-               
          Interest income       -0-     2,339       53       70       5               
          Wage income           -0-       -0-      -0-      241     678               
          Dividend income       -0-       -0-   27,967   13,627     -0-               
          NOL                   -0-    (3,038)     -0-      -0-     -0-               
          Total adjustments  60,889   140,585   48,025   98,786   6,136               
          AGI as filed      (75,805) (115,973)     -0-      -0-     -0-               
          Tax. inc. as rev. (14,916)   24,612   48,025   98,786   6,136               
                 1 Respondent disallowed all of petitioner’s reported                 
            expenses except for:  (1) The car and truck expense of $297               
            and the licenses expense of $26 reported for 1989 and (2) the             
            legal and professional expense of $356 reported for 1991.                 
          Respondent explained in the notices of deficiency that he had               
          disallowed the self-employment expenses on the basis of his                 
          determination that they were not ordinary and necessary business            
          expenses.  Respondent explained further that petitioner could               
          deduct the following amounts as itemized deductions, rather than            
          as business expenses:                                                       
          1989      1990     1991                                                     
          Mortgage interest:1                                                         
               Barnett Bank         $8,698    $6,988   $5,059                         
               SouthTrust Bank         733       350      -0-                         
               Charles Williams     25,658    33,534   32,184                         
               35,089    40,872   37,243                                              
               Taxes                 2,856       -0-      -0-                         
               Investment interest   1,808     2,339   22,144                         
               39,753    43,211   59,387                                              
                        1 The interest paid to Barnett Bank and                      
                    Charles Williams concerned mortgages on the                       
                    Oceanside Blvd. property.  The interest paid                      
                    to SouthTrust Bank concerned a mortgage that                      
                    Ms. Ihlenfeldt had on a mobile home unrelated                     
                    to the Oceanside Blvd. property.                                  










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