Diane and Frank Burkley - Page 6




                                        - 5 -                                          
               After concessions,2 the issues for decision are:  (1)                   
          Whether petitioners are entitled to deduct claimed Schedule E                
          expenses as follows:                                                         
                                   Property A              Property B                  
               Advertising         $350                 $350                           
               Auto and travel          850                  4,500                     
               Cleaning                                                                
               and maintenance          2,000                3,000                     
               Insurance                1,200                1,800                     
               Mortgage interest        7,484           13,462                         
               Repairs                  6,500           12,000                         
               Supplies                 2,000                900                       
               Taxes                    1,404                1,404                     
               Utilities                3,000                3,000                     
               Total                   24,788               40,416                     
          (2) whether petitioners are entitled to claim Schedule A itemized            
          deductions as follows:                                                       
               Medical and dental expenses              $25,000                        
               Home mortgage interest                   13,642                         
               Charitable contributions by cash                                        
               or check                                 18,000                         
               Charitable contributions other                                          
               than by cash or check                         500                       
               Unreimbursed employee expenses               13,500                     
               Total                                        70,642                     
               (3) whether petitioners failed to report rental income; (4)             
          whether petitioners are entitled to claim five dependency                    
          exemption deductions; and (5) whether petitioners are liable for             
          the accuracy-related penalty under section 6662(a).                          

               2 Petitioners concede that they are not entitled to claim:              
          (1) A $1,404 Schedule A deduction for real estate taxes; (2) a               
          $150 Schedule A deduction for personal property taxes; (3) any               
          expenses with respect to “Property C”, as listed on Schedule E of            
          their 2002 return; (4) passive activity losses of $81,120.                   
          Petitioners are also not contesting the increase in their                    
          alternative minimum tax.                                                     






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