Elliot Virgil Wilkerson - Page 7

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          The expenses consisted of automobile expenses, legal and                    
          professional services, office expense, rent, repairs and                    
          maintenance, supplies, travel, and other expenses.  Petitioner              
          attached no documentation to his revised Form 1040 to support the           
          amounts claimed for returns or allowances, cost of goods sold,              
          and expenses.                                                               
               On Schedule E, petitioner identified three rental real                 
          estate properties in Alabama:  (1) 5515 Yellow Wood Ave.,                   
          Birmingham; (2) 313 Cordova Drive, Dothan; and (3) 3312 Cathy Lou           
          Road, Dothan.  Schedule E reflected in relevant part as follows:            


          Property  Rents ReceivedExpenses Depreciation Total Expenses Losses         
          Yellow Wood $2,380      $1,836    $4,488      $6,324     ($3,944)           
          Cordova     3,960       4,222     3,599       7,821      ( 3,861)           
          Cathy Lou   2,772       8,014     2,712       10,726     ( 7,954)           
          Total       9,112       14,072   10,799                [1](12,500)          
          [1] Petitioner claimed “deductible” rental real estate losses of $3,128, $3,063, and
          $6,309 for Yellow Wood, Cordova, and Cathy Lou, respectively.  See sec. 469; see
          also Form 8582, Passive Activity Loss Limitations.                          
          The expenses consisted of cleaning and maintenance, commissions,            
          insurance, legal and professional fees, management fees, mortgage           
          interest, supplies, and taxes.  Petitioner attached no                      
          documentation to his revised Form 1040 to support the claimed               
          amounts for expenses and depreciation.                                      
               After receipt of petitioner’s revised Form 1040, respondent            
          requested from petitioner any supporting documentation concerning           
          petitioner’s claimed deductions.  Petitioner did not provide any            
          supporting documentation to respondent.                                     






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