William C. and Cheryl M. Fowler - Page 7




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               For the Florida property, petitioners had independent                  
          contractors that they would call to perform work if they were not           
          physically present to do the repairs or maintenance.  Petitioners           
          hired Katherine Morgan to landscape and Sandy Chief to perform              
          maintenance on the Florida property.                                        
               The New York property was approximately 129 acres and                  
          consisted of two houses, two storage units, a workshop, farmland,           
          and a tree plantation.  Neither of the houses on the New York               
          property was rented in 1994 and 1995.  A portion of the grounds             
          was arable and was farmed by Dan Zittle in 1994 and 1995.                   
          Petitioners did not receive any rents on the New York property in           
          1994 and received $2,326 in rent on the New York property in                
          1995.  For the New York property, petitioners hired an individual           
          to do simple tasks such as trimming around the buildings and                
          plowing snow from driveways.  Petitioners also hired an                     
          excavating contractor, a plumber, and an electrician.                       
               Petitioners claimed rental losses of $45,676 and $51,206 in            
          1994 and 1995, respectively, on their Schedule E, Supplemental              
          Income and Loss.  Petitioners did not elect to aggregate their              
          real property rental activities for purposes of section 469.                
          Interest Expense                                                            
               Respondent examined petitioners’ 1989, 1990, and 1991 income           
          tax returns and proposed adjustments to petitioners’ Schedule A,            
          Itemized Deductions, and Schedule C, Profit or Loss From                    






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