- 51 - Respondent determined that petitioner had unreported income of $1,400 in 1990 from the sale of electronics to an individual named Kenny T. We find, however, that she neither made nor lost money on these sales. She sold Mr. T. a video cassette recorder and a television for the same amount she was required to pay her supplier for these items. Although the television was returned to the supplier for a credit equal to what petitioner (and Mr. T.) had paid, there is no evidence or suggestion that petitioner retained the $1,200 that Mr. T. had paid her. We accordingly do not sustain the determination. Petitioner also paid $1,147 for items that she asserts she provided to Jennifer R. in repayment of a loan in 1990. Although petitioner has presented receipts showing her purchases in these amounts, we have only her self-serving testimony that these items were delivered to Ms. R., and Ms. R. is deceased. Respondent determined that petitioner had unreported income of $2,800 in 1990 from the rental of an apartment to an individual named Terri D. Petitioner concedes receiving $2,800 in 1990 for the short-term rental of the apartment on W. 58th Street but asserts that it was paid to Real Services and is not income to her individually. Because we have elsewhere concluded that Real Services should be disregarded for tax purposes, we hold that the $2,800 is taxable income to petitioner and sustain respondent’s determination.Page: Previous 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 Next
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