- 5 - Petitioner also carried on an activity of publishing a visitor’s guide for the geographic area of Mountain View, San Mateo, Foster City, and Half Moon Bay. Petitioner rented an apartment for 3 months in San Bruno while conducting this activity. She also rented furniture for the apartment. The cost of the furniture rental was $1,000.68. Petitioner incurred some interest expense and entertainment expense relating to the activity of publishing the visitor’s guide. Petitioner traveled sometimes to conduct this activity, but there is nothing in this record indicating the extent of the travel. Petitioner filed an individual Federal income tax return for the taxable year 2001. Petitioner attached to the return a Form 8824, Like-Kind Exchanges. Petitioner reported a realized gain of $111,715 on the sale of the San Diego condominium and a deferred gain of the same amount. Petitioner also reported on Schedule C among other items, rent or lease of vehicle of $1,001, rent of $6,000, and deductions for interest expense of $4,742. Petitioner listed the principal business as “Advertising”. In a notice of deficiency, respondent determined that petitioner was not entitled to defer the gain on the sale of the San Diego condominium. Respondent determined that petitioner should recognize a $86,857 capital gain from the sale of the San Diego condominium. The notice further disallowed certain Schedule C deductions as follows: (1) $1,001 in claimed rent orPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011