John Weller Wood, Jr., and Magdalena Frances Wood - Page 34

                                        - 34 -                                        
               For 1995, respondent made the following adjustments to the             
          itemized deductions petitioner claimed on the 1995 return:                  
          1995 Itemized Deductions      Per Return    Per Exam   Adjustment           
          Taxes                          $11,610      $11,865       ($255)            
          Home mortgage interest          23,476       32,871      (9,395)            
          Contributions                   -0-          330          (330)             
          Total                           35,086       45,066      (9,980)            
               For 1996, respondent determined that the standard deduction            
          was less than petitioner’s itemized deductions and made the                 
          following adjustments for itemized deductions:                              
          1996 Itemized Deductions      Per Return    Per Exam   Adjustment           
          Standard deduction              $6,700         -0-       $6,700             
          Itemized deductions                                                         
          Taxes                             -0-          $303        (303)            
          Home mortgage interest           -0-          8,242      (8,242)            
          Total                            6,700        8,545      (1,845)            
               Aside from petitioner’s claim that the taxes13 and mortgage            
          interest were trade or business expenses deductible on Schedules            
          C for his and Mrs. Wood’s business as dealers in real estate,               
          petitioner does not challenge respondent’s adjustments for                  
          itemized deductions.  We have found that petitioner and Mrs. Wood           
          are not dealers in real estate, and, therefore, we sustain                  
          respondent on this issue.                                                   




               13Respondent allowed petitioner to deduct on the consulting            
          business Schedule C 10 percent of the taxes as a home office                
          expense of Mr. Wood’s consulting business.                                  




Page:  Previous  19  20  21  22  23  24  25  26  27  28  29  30  31  32  33  34  35  36  37  38  Next

Last modified: May 25, 2011