- 10 - Petitioner did not report any of the above-listed deposited funds on his 1990, 1991, or 1992 returns. Furthermore, petitioner’s accountants were not aware of this business activity until after the IRS commenced its audit and investigation.12 F. Rental Property Income During 1990, 1991, and 1992, petitioner owned and held numerous real properties for investment and lease. One such property was located at 41550 Boscell Road, Fremont, California (the Boscell property). In 1990, petitioner owned 50 percent of the Boscell property with Thomas Viviano. In May 1991, Thomas Viviano sold his 50-percent interest in the Boscell property to petitioner. During the years at issue, the Boscell property was leased to two tenants. One tenant, PSB Trucking, rented space at the Boscell property for $8,400 per month. Petitioner reported rental income attributable to PSB Trucking of $50,400,13 $79,800, and $100,800 for 1990, 1991, and 1992, respectively. 12Petitioner argues that if unclaimed expense deductions are considered, his racing business lost money. 13At trial, the parties stipulated that petitioner’s share of the rental income from PSB Trucking with regard to the Boscell Road property for 1990 is $46,200, rather than the amount petitioner reported, $50,400. Respondent concedes that petitioner reported his proportionate share of the rental income attributable to PSB Trucking for 1991 and 1992.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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