M. Michael Stewart - Page 6

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               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 or            






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