Dorothy A. Wilson - Page 6




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             Property              1996            1997                               
               Marshall Lane:                                                         
              Repairs             $2,000              $1,000                         
              Auto                     ---            857                            
              Interest                 ---            4,500                          
              Taxes               ---                 4,000                          
              Yard work                ---            380                            

               On February 3, 2000, respondent mailed by certified mail a             
          notice of deficiency regarding tax years 1996 and 1997.  In his             
          notice, respondent disallowed the dependency exemption deductions           
          on the basis that petitioner failed to establish that she                   
          provided more than one-half of the support for each claimed                 
          dependent.  Respondent also disallowed the deduction for medical            
          expenses based upon a failure to substantiate the expenses.                 
               Respondent also disallowed all of the above-listed expenses            
          for 1996 for all of the properties.  Respondent allowed interest            
          expenses of $6,795 for the Douglas Way property and $3,737 for              
          the Marshall Lane property.  Petitioner did not claim these                 
          interest deductions on her 1996 Federal income tax return.                  
               As for 1997, respondent disallowed all of the above-listed             
          expenses for the Washington and Park Place properties.                      
          Respondent disallowed $514 of the auto expense and the remaining            
          above-listed expenses for the Douglas Way property.  Respondent             
          also disallowed $514 of auto expenses, $3,284 of taxes, and the             
          remaining above-listed expenses for the Marshall Lane property.             
          Respondent allowed an additional interest deduction of $1,070 for           






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