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from the record, the $10,000 fine was paid by petitioner during
1993.
On June 30, 1993, petitioner sold a condominium located at
2793 Chateau Circle, Columbus, Ohio (the condominium), that he
used as his residence for an unspecified period.1 Thereafter, he
moved into an apartment in an 18 unit apartment building located
at 104 W. Main Street, Columbus, Ohio (the apartment building)
that he owned.2 Some or all of the other apartments in the
apartment building were rented out, or held for rent by
petitioner during 1993.
Petitioner prepared his 1993 Federal income tax return.
Included with that return are: (1) A Schedule E, Supplemental
Income and Loss; (2) a Schedule C, Profit or Loss From Business;
and (3) a Form 2119, Sale of Your Home.
The income and deductions attributable to the apartment
building are reported on the Schedule E as follows:
1 Petitioner’s 1988 Federal income tax return, dated
October 15, 1989, lists 85 East Gay St., Suite 804, Columbus,
Ohio, as his then present home address. His 1989 Federal income
tax return, dated July 31, 1990, indicates that as of that date
his home address was the address of the condominium.
2 A review of petitioner’s Federal income tax returns
indicates that he has owned the apartment building since at least
1987. A Schedule E, Supplemental Income Schedule, included with
petitioner’s 1987 Federal income tax return, lists the apartment
building as rental property.
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