T.C. Memo. 2000-32
UNITED STATES TAX COURT
WILLIAM WARREN KELLY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2457-98. Filed January 28, 2000.
William Warren Kelly, pro se.
Robert V. Boeshaar, for respondent.
MEMORANDUM OPINION
POWELL, Special Trial Judge: Respondent determined
deficiencies in petitioner's 1993 and 1994 Federal income taxes
in the amounts of $1,631 and $2,014, respectively. The issue is
whether petitioner's aircraft leasing activity is a passive
activity under section 469.1 Petitioner resided in Springfield,
Oregon, at the time he filed his petition.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue.
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