- 14 - made those determinations because petitioners did not establish their entitlement to a casualty loss deduction for 1997. Respondent also determined in the notice that petitioners realized a long-term capital gain of $211,000 for 1995 from the sale of the condo and that they understated the amount of such gain in their 1995 joint return by $185,796. In determining that petitioners realized $211,000 from the sale of the condo, respon- dent determined that petitioners’ adjusted basis in the condo at the time of its sale was zero. Respondent further determined in the notice to disallow rental expense deductions of $29,383 and $17,438 claimed in Schedules E of the 1996 and 1997 joint returns, respectively. Respondent made those determinations because petitioners did not establish that the deductions claimed were for amounts (1) that petitioners expended or (2) that petitioners expended for the purpose(s) claimed. Respondent also determined in the notice to disallow a mortgage interest deduction of $21,846.03 in Schedule A of the 1996 joint return. Respondent made that determination because petitioners did not establish that the deduction claimed was for an amount (1) that petitioners expended or (2) that petitioners expended for the purpose claimed. Respondent further determined in the notice that petitioners are liable for each of the years at issue for the accuracy-Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011