William W. Brown - Page 3
- 2 -
be entered is not reviewable by any other court, and this opinion
shall not be treated as precedent for any other case.
Respondent determined a deficiency in Federal income tax of
$3,169 for petitioner’s 2001 tax year. After concessions,2 the
issue we must decide is whether petitioner is entitled to deduct
payments totaling $3,484.16 toward the principal of an
outstanding debt reported on his Schedule C, Profit or Loss From
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated by this reference. When the petition was filed,
petitioner resided in Egg Harbor Township, New Jersey.
Petitioner has been a residential home builder since 1985.
On December 22, 1988, petitioner purchased five vacant lots
(lots) in Egg Harbor Township, New Jersey, for $162,500. In
order to pay for the lots, petitioner borrowed $182,500 from
2 Respondent concedes that petitioner is entitled to deduct
$8,515.84 for mortgage interest reported on his Schedule C. The
parties stipulate that petitioner is not entitled to a deduction
for mortgage interest reported on his Schedule A, Itemized
Deductions, but he is entitled to the $6,550 standard deduction
for 2001. The parties also agree that petitioner is entitled to
a Schedule C business deduction of $2,033, instead of the claimed
$984, for business use of home and a lifetime learning credit of
$716, instead of the claimed $223, for 2001. Whether petitioner
is liable for additional self-employment tax or entitled to an
earned income credit for 2001 are computational adjustments that
will need to be made in the parties’ Rule 155 computations.
Page: 1 2 3 4 5 6 7
Last modified: November 10, 2007