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On their Schedule A, petitioners claimed as follows, in
pertinent part:
Itemized Deductions Amount
Line 1 Medical and dental expenses$21,358
Line 4 Net medical deduction 16,175
Line 5 State and local income taxes 1,630
Line 6 Real estate taxes 3,456
Line 9 Total taxes 5,086
Line 10 Mortgage interest (financial) 4,937
Line 14 Total interest deduction 4,937
Line 18 Total contributions 2,000
Line 23 Total limited misc. expenses 33,785
Line 26 Net limited misc. deduction 32,403
Line 28 Total itemized deductions 60,603
As shown above, petitioners claimed a Schedule A deduction
for real estate taxes paid of $3,456 on their 1999 Federal income
tax return. During taxable year 1999 petitioners owned four
distinct properties. The first property was located in the
Bahamas. This property was inherited by petitioner from his
mother when she passed away in 1980. This property consisted of
a vacant lot, which had been zoned for duplexes. Petitioners
owned two pieces of property located in Punta Gorda, Florida.
One of these properties was located 10 miles from Port Charlotte
and was inherited from petitioner’s mother. The other property
was purchased by petitioners and was located about 10 miles from
the first Florida property. The fourth property owned by
petitioners was their principal residence, located in Chicago,
Illinois. This property was situated on two adjoining tracts of
land. The real estate taxes on the Chicago property were paid
through petitioners’ mortgage loan with EMC Mortgage Corporation.
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