- 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 NextLast modified: May 25, 2011