Zabetti A. Pappas - Page 51




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               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.                                                 






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