Diane and Frank Burkley - Page 3




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          precedent for any other case.  Unless otherwise indicated,                   
          subsequent section references are to the Internal Revenue Code in            
          effect for the year in issue, and all Rule references are to the             
          Tax Court Rules of Practice and Procedure.                                   
               Respondent determined a $10,048 deficiency in petitioners’              
          Federal income tax for 2002 and a $2,009.60 accuracy-related                 
          penalty under section 6662(a).                                               
               The deficiency resulted from respondent’s disallowance of:              
          (1) $12,000 deducted as an other miscellaneous deduction for                 
          “home winterization” on Schedule A, Itemized Deductions, and (2)             
          the following expenses claimed on Schedule E, Supplemental Income            
          and Loss, for rental Property B (identified as an “apartment                 
          building” located at 8314 South Green Street):                               
                    Advertising               $350                                     
                    Auto and travel                4,500                               
                    Cleaning and maintenance       3,000                               
                    Repairs                        12,000                              
                    Supplies                       900                                 
                    Utilities                      3,000                               
               Petitioners attached a Schedule E to their Federal income               
          tax return for 2002 showing three properties as follows:  (1)                
          Property A, a “2-flat building” located at 8314 South Green                  
          Street; (2) Property B, an “apartment building” located at 8314              
          South Green Street; and (3) Property C, an “apartment building”              
          located at 8314 South Green Street.                                          
               In the deficiency computation, respondent increased the                 
          amount of the alternative minimum tax shown on the return and                






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