- 2 - After concessions,1 the issues for decision are: (1) Whether the deductions petitioners claimed on their 1996 and 1997 Federal income tax returns with respect to the rental of rooms in their personal residence are subject to the limitation imposed by section 280A(c)(5); and (2) whether petitioners properly calculated depreciation expenses with respect to their rental activity. Background The stipulation of facts and the accompanying exhibits are incorporated herein by reference. Petitioners resided in Wayne, Pennsylvania, at the time their petition was filed with the Court. In 1983 petitioners paid $125,000 for a 1-acre property in Radnor Township, Pennsylvania. The property includes the following improvements: a three-story, 4500 square foot Victorian style house (main house); a two-story, 1200 square foot carriage house (carriage house); landscaped grounds; a swimming pool; and a pool house with shower facilities and a full kitchen. 1 Petitioners concede respondent’s adjustment to their Schedule C, Profit or Loss From Business, depreciation. Respondent concedes that petitioners are entitled to Schedule C deductions for entertainment and travel expenses and that petitioners are entitled to deduct $5,231 of legal expenses incurred in connection with their residential rental activity. The adjustments to itemized deductions in the notice of deficiency are computational adjustments which will be affected by the outcome of the other issues to be decided.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011