Philip A. Saunders - Page 4




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          rented (portions of 1991 and 1992) petitioner filed Federal                 
          income tax returns as a married individual filing a separate                
          return.  With each return petitioner included a Schedule A,                 
          Itemized Deductions, on which he claimed deductions for home                
          mortgage interest and real estate taxes attributable to the                 
          Pepper Pike residence.  Apparently, neither he nor his spouse               
          reported any rental income attributable to the Pepper Pike                  
          residence during those years.                                               
               Petitioner’s Federal income tax return for each year in                
          issue, as well as the Federal income return of his spouse for               
          each of those years, was prepared by petitioner.  Included with             
          petitioner’s return for each year is a Schedule E, Supplemental             
          Income and Loss, on which the following items attributable to the           
          Pepper Pike residence are reported:                                         
                                             1993           1994                      
          Income:                            - 0 -          - 0 -                     
          Expenses:                                                                   
               Advertising                   $249.06   $83.03                         
               Auto and travel               420            140                       
               Cleaning and maintenance     2,852.77       950.92                     
               Insurance                     446          149                         
               Mortgage interest paid                                                 
               to banks                 17,383.71     5,794.23                        
               Other interest                161.52        53.84                      
               Repairs                       737.59       245.86                      
               Taxes                    3,074.46     1,024.82                         
               Utilities                1,830.23       610.08                         
               Depreciation             4,357.70     1,452.57                         
                    Total expenses      31,513.04    10,504.35                        






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