Steven K. Stoddard and Ellen M. Stoddard - Page 11




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          rental income of $4,385.20 and claimed rental expense deductions            
          of $29,382.66, which included $8,806.68 for claimed depreciation,           
          and a 1996 Schedule E loss of $24,997.46.                                   
               The 1997 joint return included Schedule A.  In the 1997                
          Schedule A, petitioners claimed, inter alia, a casualty loss                
          deduction of $138,256 with respect to the Quissett.  As required,           
          petitioners filed Form 4684, Casualties and Thefts (Form 4684),             
          with the 1997 joint return.  In section A of Form 4684, Personal            
          Use Property, petitioners indicated (1) that the “Cost or other             
          basis” of the Quissett was $144,990, (2) that they had no “Insur-           
          ance or other reimbursement” with respect to the Quissett,                  
          (3) that they had no gain from casualty or theft, (4) that the              
          fair market value before the casualty or theft of the Quissett              
          was $175,000, (5) that the fair market value of the Quissett                
          after the casualty or theft was $22,000, and (6) that the amount            
          of the casualty loss with respect to the Quissett, after applying           
          certain limitations, was $138,256.                                          
               The 1997 joint return also included Schedule E.  With                  
          respect to the Doon Way residence, the 1997 Schedule E reported             
          no rents received and claimed rental expense deductions of                  
          $17,438, consisting of $391 for claimed advertising, $834 for               
          claimed cleaning and maintenance, $375 for claimed insurance,               
          $1,200 for claimed utilities, and $14,638 for claimed deprecia-             
          tion, and a 1997 Schedule E loss of $17,438.                                







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