Diane and Frank Burkley - Page 5




                                        - 4 -                                          
              The meeting adjourned with no agreed-upon stipulation.                  
               On May 17, 2005, respondent received (via facsimile) from               
          petitioners a set of documents that included petitioners’ 2002               
          Forms W-2, Wage and Tax Statement, petitioners’ joint 2002 Form              
          1040, U.S. Individual Income Tax Return, a joint Form 1040X,                 
          Amended U.S. Individual Income Tax Return for 2002, and pictures             
          of the South Green Street property and another rental property               
          located at 11036 South Vernon Avenue.                                        
               On the basis of these documents, and pursuant to an order of            
          this Court dated May 23, 2005, respondent filed an answer on July            
          29, 2005, in which respondent raised numerous new issues that                
          resulted in an increased deficiency and a section 6662(a)                    
          accuracy-related penalty.  The answer raised the following new               
          issues:  (1) Unreported rental income; (2) disallowance of five              
          dependency exemption deductions; (3) unreported income from a                
          State income tax refund; (4) disallowance, in total, of itemized             
          Schedule A deductions for (a) medical and dental expenses, (b)               
          real estate taxes, (c) personal property taxes, (d) home mortgage            
          interest, (e) gifts to charity, and (f) unreimbursed employee                
          business expenses; (5) disallowance in total of all Schedule E               
          deductions; and (6) disallowance of rental and real estate loss              
          because of passive activity loss limitations.                                










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