Luis Acle, Jr. - Page 3

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               Respondent determined a deficiency in petitioner’s Federal             
          income tax of $40,818, and an accuracy-related penalty of                   
          $7,683.20, for the taxable year 1998.                                       
               The issues for decision are:  (1) With respect to                      
          petitioner’s rental activities, whether the losses petitioner               
          incurred are subject to the passive activity loss limitations of            
          section 469; (2) with respect to petitioner’s business                      
          activities, (a) whether petitioner received unreported income as            
          determined by respondent, and (b) whether petitioner is entitled            
          to a business expense deduction disallowed by respondent; and (3)           
          whether petitioner is liable for the accuracy-related penalty               
          under section 6662(a).  The adjustments in the notice of                    
          deficiency to the itemized deductions and to the self-employment            
          income tax and the deduction therefor are computational and will            
          be resolved by the Court’s holding on the issues.                           
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  Petitioner resided in San           
          Diego, California, on the date the petition was filed in this               
          case.                                                                       
               Petitioner filed a Federal income tax return for taxable               
          year 1998 with the filing status of head of household.                      
          Petitioner reported $300 of interest income, a $6,760 business              
          loss, and a $62,297 loss from rental activities, for an adjusted            






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