Sidney C. Shaw - Page 12




                                       - 12 -                                         
          Shaw’s Gulf deducted the rental expense and all the repairs and             
          maintenance expense relating to the airplane.  Petitioner                   
          included the rental income and deducted the mortgage interest and           
          depreciation expense related to the airplane.                               
          Tax Reporting                                                               
               Petitioner’s individual tax return and the tax returns of              
          petitioner’s business entities were prepared by petitioner’s                
          accountant, who was a certified public accountant, tax                      
          practitioner, and had a real estate background.  Petitioner met             
          with his accountant regularly and discussed his business                    
          activities.                                                                 
               On petitioner’s Schedule E, Supplemental Income and Loss, he           
          reported income and losses from his ownership interests as                  
          nonpassive:                                                                 
                Entity                             1995        1996                   
                RS&M                           $29,814   $29,814                      
                R&S                            27,869    25,236                       
                SDQ LLC                        21,981    19,247                       
                Shaw, Ltd.                      (139,623)  (108,691)                  
                Net nonpassive income/(loss)  $(59,959)  $(34,394)                    
               Based on petitioner’s assumption that he qualified as a real           
          estate professional under section 469(c)(7), petitioner reported            
          his net income and loss from his rental property on Schedule E as           
          nonpassive:                                                                 










Page:  Previous  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  Next

Last modified: May 25, 2011