Herbert L. Whitehead and Jennifer L. Whitehead - Page 22




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               Petitioners’ 1996 joint return included Schedule A, Itemized           
          Deductions (Schedule A).  In that schedule, petitioners claimed,            
          inter alia, the following deductions:  (1) $7,124 for real estate           
          taxes, (2) $36,022 for mortgage interest,14 and (3) $79 for                 
          points not reported in Form 1098.15                                         
               Petitioners’ 1996 joint return also included Schedule SE.              
          In that schedule, petitioners reported self-employment income               
          attributable to Ms. Whitehead of $6,600.                                    
               In petitioners’ 1996 joint return, petitioners claimed,                


               12(...continued)                                                       
          Whitehead (Mr. Whitehead’s 1996 Form W-2).  That form showed                
          “BURIEN NISSAN ADMINISTRATION” as employer and Mr. Whitehead as             
          employee.  Mr. Whitehead’s 1996 Form W-2 showed, inter alia,                
          “Wages, tips, other compensation” in the amount of $109,721.77.             
          That form indicated that that amount included a benefit of $1,800           
          that was identified in that form as “EPV”.  Although not alto-              
          gether clear, we believe “EPV” stands for “employer provided                
          vehicle”.                                                                   
               13Petitioners included in petitioners’ 1996 joint return a             
          statement in which petitioners provided certain information with            
          respect to the “Other income” reported in that joint return.  In            
          that statement, petitioners listed the following items as “Other            
          income”:  (1) Income of $1,625 from Bulldog Alarms, (2) income of           
          $6,600 from Burien Nissan as shown in Schedule SE, Self-Employ-             
          ment Tax (Schedule SE), that petitioners included in their 1996             
          joint return, and (3) income of $750 from Burien Nissan.                    
               14Petitioners’ 1996 joint return included a statement in               
          which petitioners reported that $28,071 of the total mortgage               
          interest deduction that they claimed was attributable to Home               
          Servicing and $7,951 of that deduction was attributable to                  
          Colonial Mortgage.                                                          
               15The $79 deduction claimed for points not reported in Form            
          1098 represented petitioners’ amortization of points that they              
          claim they paid with respect to the refinancing of the Kirkland             
          property in February 1994.                                                  





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