- 4 - return * * * signed under oath.” The purported return is dated September 8, 2002–-2 days before trial. On line 18 (“Rents, royalties, partnerships, estates, trusts, etc.”) of the purported return, petitioner listed $445,354 of net rental income--a significantly greater amount than respondent had determined in the notice of deficiency--representing $1,212,140 of rents received, reduced by $98,499 of depreciation expense and $668,287 of other rental expenses. On line 15 (“Other gains or (losses)”) of the purported return, petitioner listed $2,283,273 of alleged losses which he contends resulted from “involuntary conversion” of his forfeited rental properties. After trial, with leave of the Court, respondent filed an amendment to his answer, asserting an increased deficiency and additions to tax in conformity with the evidence that petitioner’s 1988 net rental income is $445,352.4 Petitioner has not sought to retract or disavow his admissions on the purported return as to the amounts of his gross rental income, rental depreciation expense, and other rental expenses. He argues, however, that his net rental income is more than offset by the $2,283,273 of losses that he claimed on the purported return. 4 Respondent attributes to rounding the $2 difference between the amounts of net rental income indicated on the purported return and as calculated in the amended answer.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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