Joyce H. Sams - Page 5




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               In addition to her work as a real estate agent, petitioner             
          was involved with other real estate matters in 1996, both as an             
          individual and purportedly on behalf of Sams, Inc.  On occasion,            
          petitioner taught real estate classes for O’Brien.  Petitioner              
          owned two rental properties in Waldorf, Maryland.  In addition,             
          petitioner also maintained and managed rental property by finding           
          and placing tenants for Skyview Farm and managed real estate                
          property for Bill Stallman (the Stallman property).  Petitioner             
          received rental checks from the tenants of Skyview Farm and the             
          Stallman property, deposited the checks into her personal                   
          checking (the account), and wrote checks to Skyview Farm and Bill           
          Stallman for the amount of the rents paid by the tenant minus her           
          management fee.                                                             
               On Form 1040, U.S. Individual Income Tax Return, for 1996              
          petitioner reported income and claimed deductions as follows:               
                    Income                                                            
               Taxable interest                        $341                           
               Rental real estate, royalties,          (10,576)                       
               partnerships, S corporations,                                          
               trusts, etc.                                                           
               Other income (Net operating loss        (56,699)                       
               carryover)                                                             
               Adjusted gross income (negative)        (66,934)                       
               Petitioner reported income and claimed deductions on                   
          Schedule E attached to her individual return as follows:                    









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