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house, the un

developed land in Florida, and the timeshares and a

loss on the s

ale of the Florida house) totaling $121,966 in 1994,

$72,546 in 19

95, and $345,223 in 1996 claimed by petitioner and

Mrs. Wood on

the property management Schedules C, (4) disallowed

losses of $3,

431 for 1994, $809 for 1995, and $1,578 for 1995

claimed on th

e distributorship Schedules C, (5) allowed

petitioner de

ductions on Schedule E for expenses relating to the

consulting bu

siness by $24,016 for 1994, $7,037 for 1995, and

$13,094 for 1

996, consisting of omitted gross receipts and

disallowed cl

aimed business expenses, (3) disallowed net losses

claimed on th

e property management Schedules C, (6) made

adjustments t

o Schedule A itemized deductions, (7) disallowed

(for expenses

attributable to the New Jersey house, the Florida

rental of the

New Jersey house before its sale that had been

1994 return),

  • -

    12 -

    • (2)

      increased petitioner’s profits from his

$19,032 of

the $19,233 loss from the sale of a Buick LeSabre

petitioner

claimed on Form

4797 of the 1996 return, (8)

determined

that petitioner

was liable for self-employment taxes

on the net

profit from his

consulting business and allowed

petitioner

a deduction for

half of those taxes, (9) allowed

petitioner

a net operating

loss carryover of $18,520 to 1994, and

(10) disallowed the net operating loss carryover of $36,389

petitioner claimed on the 1996 return.

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