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Mark Wagner - lease $634.00
Brodey Pharmacy $8,088.57
Labor $20,180.00
Rental Utilities $485.00
Tooley Drug $1,940.42
Oakwood Nursing Home $18,598.89
Episcopal Church $1,200.00
Building Supplies $28,624.00
Aunt Lorraine’s Health Ins. $1,092.00
Taxes $8,699.29
$89,542.17
Respondent issued to petitioners a notice of deficiency
(notice) for their taxable years 2000 and 2001. In that notice,
respondent determined, inter alia, that $26,971.69 of the total
expenses of $61,654 that petitioners claimed in the 2000 Schedule
E and $39,083 of the total expenses of $89,542 that petitioners
claimed in the attachment to the 2001 Schedule E and the second
attachment to the 2001 Schedule E must be capitalized and amor-
tized. In the notice, respondent also determined that petition-
ers are liable for each of their taxable years 2000 and 2001 for
the accuracy-related penalty under section 6662(a).
OPINION
Petitioners bear the burden of proving that the determina-
tions in the notice are erroneous.2 Rule 142(a); Welch v.
2Petitioners do not claim that the burden of proof shifts to
(continued...)
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Last modified: November 10, 2007