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For 1995, respondent

made the followi

ng adjustments to the

itemized deductions petit

ioner claimed on

the 1995 return:

1995 Itemized Deductions

Per Return

Per Exa

m

Adjustment

Taxes

$11,610

$11,865

($255)

Home mortgage interest

23,476

32,871

(9,395)

Contributions

-0-

330

(330)

Total

35,086

45,066

(9,980)

For 1996, respondent

determined that

the standard deduction

was less than petitioner’

s itemized deduct

ions and made the

following adjustments for

itemized deducti

ons:

1996 Itemized Deductions

Per Retu

rn

Per Exam

Adjustment

Standard deduction Itemized deductions Taxes Home mortgage interest Total

$6,700

-0-

$6,700

-0- -0- 6,700

$303 8,242 8,545

(303) (8,242) (1,845)

Aside from petitioner’s claim that the taxes13 and mortgage

interest were trade or business expenses deductible on Schedules

C for his and Mrs. Wood’s business as dealers in real estate,

petitioner does not challenge respondent’s adjustments for

itemized

deductions.

We

have

found

that

petitioner

and

Mrs.

Wood

are not dealers in real estate, and, therefore, we sustain

respondent on this issue.

13Respondent allowed petitioner to deduct on the consulting business Schedule C 10 percent of the taxes as a home office expense of Mr. Wood’s consulting business.

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