Dennis E. and Paula W. Lofstrom - Page 6

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          Bed and Breakfast and Writing Activity Deductions                           
               Petitioners also deducted expenses related to a B&B that               
          they listed as their principal trade or business on Schedule C,             
          Profit or Loss from Business, for 1997.  Petitioners called the             
          B&B, “Angel’s Rest Arrowhead Ranch - Fly In Bed And Breakfast”              
          and listed related gross receipts of $649 and expenses of                   
          $19,158.4  Petitioners allowed Mr. Lofstrom’s daughter and her              
          family to use the B&B rent-free for an unspecified period of time           
          that same year.  Petitioners failed to introduce any evidence               
          that they rented the B&B to anyone else.                                    
               In addition, petitioners deducted expenses for                         
          Mr. Lofstrom’s writing activities in 1997 and 1998.                         
          Specifically, petitioners deducted $1,664 for travel expenses and           
          writing supplies in 1997 and $8,413 in 1998.                                
               Respondent mailed petitioners a deficiency notice on                   
          December 20, 2002, disallowing their $29,000 alimony deduction              
          for 1997, B&B-related deductions for 1997, and writing activity             
          deductions for 1997 and 1998.  Petitioners timely filed a                   
          petition with the Court.                                                    
                                     Discussion                                       
               We must decide whether Mr. Lofstrom’s transfer of a contract           
          for deed constitutes deductible alimony.  We must also decide               

               4Of this amount, $12,622 is depreciation expenses, which               
          petitioners concede.                                                        






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