Dennis E. and Paula W. Lofstrom - Page 2

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                    2.  Held, further, Ps may not deduct expenses for                 
               a hotel or like establishment because they used the B&B                
               for personal purposes for an indeterminate amount of                   
               time, and they failed to substantiate the expenses.                    
               Sec. 280A (c)(1), (d)(1), (f)(1)(B), (g).                              
                    3.  Held, further, Ps may not deduct writing                      
               activity expenses where they failed to show that H was                 
               engaged in the activity of writing for profit.  Secs.                  
               162, 183; sec. 1.183-2(a), Income Tax Regs.                            


               Steven Z. Kaplan, for petitioners.                                     
               Melissa J. Hedtke, for respondent.                                     


                                       OPINION                                        

               KROUPA, Judge:  Respondent determined a $10,552 deficiency             
          in petitioners’ Federal income tax for 1997 and a $2,198                    
          deficiency for 1998.  After concessions,1 the issues for decision           
          are:                                                                        
               1.  Whether petitioners may claim an alimony deduction for             
          $29,000 in 1997 for the transfer of a contract for deed.  Because           
          we find the contract for deed does not constitute cash or a cash            
          equivalent, we hold that they may not.                                      



               1Petitioners conceded several deductions, including auto               
          expenses, legal expenses for Mr. Lofstrom’s divorce, real estate            
          appraisal expenses, closing costs, flood insurance recovery                 
          costs, tax return preparation fees, land abstract costs,                    
          utilities, travel expenses, and other expenses claimed on                   
          Schedule F, Profit or Loss From Farming, and Schedule C, Profit             
          or Loss From Business.                                                      



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