General K. Hilliard and Ida M. Hilliard - Page 2

               After concessions1 by the parties, the issues remaining for            
          our consideration are:  (1) Whether petitioners are entitled to             
          deduct losses from charter activities of two boats, which were              
          passed through to petitioners from their wholly owned S                     
          corporation, "Island Ventures, Inc."; (2) whether petitioners are           
          entitled to deduct losses attributable to the rental of                     
          residential property located in the Lake Tahoe area (the Tahoe              
          property); (3) whether petitioners are entitled to deduct                   
          automobile expenses attributable to Mrs. Hilliard's self-                   
          employment activity in an amount greater than that allowed by               
          respondent and, if not, whether petitioners are liable for                  
          additional self-employment tax; (4) whether petitioners are                 
          entitled to deduct mortgage interest in an amount greater than              
          that allowed by respondent; (5) whether petitioners are liable              
          for additions to tax for negligence; and (6) whether petitioners            
          are liable for additions to tax for substantial understatement of           
          their tax liability.                                                        
               The question of whether petitioners are entitled to deduct             


               1 Petitioners conceded that: (1) Respondent's $11,992                  
          investment tax credit recapture adjustment for 1987 is correct;             
          (2) respondent's adjustments regarding the Tahoe property in                
          items d, e, and i in the Adjustment to Income (Supplemental                 
          Schedule) in the notice of deficiency are correct if the Court              
          should find that the Tahoe rental activity was not for profit               
          under sec. 183, I.R.C., and if the activity was for profit, then            
          the loss limitations of sec. 280A(e), I.R.C., would apply; (3)              
          they are not entitled to an interest deduction for $7,153 of                
          points claimed for 1987; (4) $2,625 of interest claimed for 1987            
          with respect to the Tahoe property is not allowable; (5) $1,385             
          of the investment interest claimed for 1988 is not allowable; and           
          (6) $460 of personal interest claimed for 1987 is not allowable.            



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