Dorothy A. Wilson - Page 5




                                        - 4 -                                         
          Federal income tax return, petitioner claimed a dependency                  
          exemption deduction for Mr. Ivey.                                           
               For 1997,3 petitioner reported income from rents of $3,720             
          for the Washington property, $3,000 for the Douglas Way property,           
          and $1,800 for the Marshall Lane property.  Petitioner did not              
          report income for the Park Place property.  Petitioner deducted             
          the following relevant amounts for her various properties for tax           
          years 1996 and 1997 on Schedules E:                                         
             Property              1996            1997                               
               Washington:                                                            
              Repairs        $2,200                   $2,150                         
              Taxes               800            4,400                               
              Utilities                480            ---                            
              Pest control        ---                 1,100                          
              Yard work                ---            480                            
               Park Place:                                                            
              Rental expenses        5,380           2,381                           
               Douglas Way:                                                           
              Repairs             650                 600                            
              Legal               1,000               ---                            
              Auto                ---                 857                            
              Interest                 ---            3,900                          
              Pest control        ---                 400                            
              Yard work                ---            1,000                          







               3    The first page of petitioner’s 1996 Federal income tax            
          return indicates that petitioner reported a net loss of $6,337 on           
          Schedule E, Supplemental Income and Loss.  However, the record              
          does not contain the Schedule E.                                            





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