Dennis E. and Paula W. Lofstrom - Page 3

                                        - 3 -                                         
               2.  Whether petitioners may deduct $19,158 in 1997 for                 
          expenses incurred in the operation of a bed and breakfast (B&B).            
          Because we find they used the B&B for personal purposes for an              
          indeterminate period and failed to substantiate expenses, we hold           
          that they may not deduct these expenses.                                    
               3.  Whether petitioners may deduct $1,664 in 1997 and $8,413           
          in 1998 for expenses related to Mr. Lofstrom’s writing                      
          activities.  Because we find they failed to show that                       
          Mr. Lofstrom engaged in the activity of writing for profit, we              
          hold that they may not deduct these expenses.                               
                                     Background                                       
               The parties submitted the case fully stipulated under Rule             
          122.2  The stipulation of facts and accompanying exhibits are               
          incorporated by this reference and are so found.  Petitioners               
          resided in Overland Park, Kansas, at the time they filed this               
          petition.                                                                   
               Trial was first scheduled for June 14, 2004, but was                   
          continued because petitioners were in Africa.  Trial was then               
          rescheduled for June 6, 2005.  Although petitioners were                    
          represented by counsel, they were not present to testify or be              
          cross-examined.  We admitted several documents at trial,                    


               2All section references are to the Internal Revenue Code in            
          effect for the years in issue, and all Rule references are to the           
          Tax Court Rules of Practice and Procedure, unless otherwise                 
          indicated.                                                                  




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  Next

Last modified: May 25, 2011