Estate of Lorraine C. Disbrow, Deceased, Martha D. Johnson, Executrix - Page 21

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          returns reports that Funny Hats’ principal business activity was            
          “rental” and that its principal product or service was “real                
          estate”.  None of those returns reports any rent for those years.           
          The 2001 return reports that Funny Hats realized $277 of interest           
          income during 2001 and was entitled to claim $1,153 in                      
          “miscellaneous” deductions.  The 2002 return reports that Funny             
          Hats realized $47 of interest income during 2002 and was entitled           
          to claim $843 in “miscellaneous” deductions.  The 2003 return               
          reports that this return was a final return and that Funny Hats             
          had realized $29 of interest income during 2003.                            
          13.  Estate Tax Return and Notice of Deficiency                             
               On or about May 3, 2001, Martha Johnson filed a Federal                
          estate tax return for decedent’s estate.  The return reports in             
          part that decedent’s estate owes Funny Hats $8,500 for the                  
          “Balance of annual rent due pursuant to lease agreement” and that           
          decedent’s estate incurred a $6,000 expense for the “Clean out              
          and removal of property re:  Decedent’s home”.  By notice of                
          deficiency dated February 10, 2004, respondent determined the               
          estate tax deficiency in issue.  The parties now agree that                 
          decedent’s estate is not entitled to deduct any of the $8,500 as            
          rent payable to Funny Hats and that decedent’s estate is entitled           
          to deduct only $342.04 as a cleaning expense.                               









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