John Weller Wood, Jr., and Magdalena Frances Wood - Page 33

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          that the new purpose was for the production of income.  Sec.                
          1.165-9(b)(1), Income Tax Regs.                                             
               Petitioner and Mrs. Wood purchased the Florida lot with the            
          intent to build their personal residence on it.  Petitioner and             
          Mrs. Wood used the Florida house as their personal residence                
          until it was sold in 1996.  The property was never rented or                
          otherwise changed to income-producing property.  See, e.g.,                 
          Newcombe v. Commissioner, 54 T.C. 1298, 1301-1302 (1970); Newbre            
          v. Commissioner, T.C. Memo. 1971-165.                                       
               In sum, we hold that petitioner is not entitled to deduct              
          any loss on the foreclosure of the Florida house.  We have                  
          considered all of petitioner’s arguments regarding the disallowed           
          expenses and loss claimed on the property management Schedules C,           
          and to the extent not specifically addressed, we find them                  
          unpersuasive.                                                               
          V.   Schedule A Itemized Deductions                                         
               For 1994, respondent made the following adjustments to the             
          itemized deductions petitioner claimed on the 1994 return:                  
          1994 Itemized Deductions      Per Return    Per Exam   Adjustment           
          Medical & dental                $1,365         -0-       $1,365             
          Taxes                           24,424      $12,456      11,968             
          Home interest                   42,614        6,632      35,982             
          Contributions                     -0-           304        (304)            
          Miscellaneous                    -0-         6,488       (6,488)            
          AGI limitation                  –-           (215)       (215)              
          Total                           68,403       25,665      42,738             







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