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Petitioner alleges that only fees of $1,455 from property
management rents of $14,950 deposited into the account are
includable in gross income because she was a collection agent for
which she received a fee. Petitioner’s bank statements indicate
that deposits of $6,150 from the Skyview Farm tenant and $10,300
from the Stallman property tenant were made into the account.
Canceled checks written on the account indicate that petitioner
paid $5,542 to Skyview Farm and $9,453 to Bill Stallman. We
conclude that petitioner retained $608 and $847, respectively,
totaling $1,455 of fees received that are includable in
petitioner’s gross income.
Petitioner argues that only one-fourth of the deposit of
$7,500 as shown on the partnership agreement is includable in
gross income. Although the relevant partnership agreement
indicates that petitioner had a one-fourth interest in the assets
of the partnership capital and for purchases and sales, profits,
losses, and distributions, petitioner did not present any
credible evidence that she distributed any of $7,500 that she
received pursuant to the partnership agreement to the other
partners. We note that the record contains neither a return for
this partnership nor a Schedule K-1 issued by this partnership to
petitioner reflecting the distribution of income. We conclude
that the entire deposit of $7,500 is includable in petitioner’s
gross income.
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