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recomputed the amount of itemized deductions allowable, taking
into account the limitations due to adjusted gross income under
section 67.
This case was originally set for trial on May 23, 2005. In
anticipation of trial, respondent’s counsel suggested that the
parties meet at respondent’s office. The parties met on May 12,
2005. During this meeting, respondent informed petitioner Diane
Burkley (Mrs. Burkley) and petitioners’ return preparer, Horace
Ingram (Mr. Ingram), about Rule 91 (requiring parties to
stipulate all facts, documents, and evidence not in dispute). In
response to this exchange, Mr. Ingram replied: “rules are made
to be broken”.
During the above meeting, Mr. Ingram redefined the
properties listed on petitioners’ Schedule E with the following
information: (1) Property A, and all expenses listed for it,
pertained to a single-family residence located at 8314 South
Green Street; (2) Property B, and all expenses listed for it,
pertained to a multiunit building located on South Vernon Avenue,
and (3) Property C, which was originally described on
petitioners’ Schedule E as an “apartment building” located at
8314 South Green Street, was included by error on Mr. Ingram’s
part, and all income and expenses listed for this property should
be disregarded.
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Last modified: March 27, 2008