the losses from boat chartering and residential rental activities concerns whether those endeavors were "not engaged in for profit" within the meaning of section 183.2 For simplicity and clarity, we set forth the background facts and legal principles applying generally to the boating and residential rental activities. Thereafter, combined findings of fact and legal discussion are presented in separate sections for each issue. I. Background3 Petitioners, at all relevant times, were married, filed joint income tax returns, and resided in Orinda, California. Petitioners are medical doctors: Mrs. Hilliard is a psychiatrist and Mr. Hilliard is a cardiologist. They practice medicine on a full-time basis. Mr. Hilliard has been involved in sailing as a hobby since 1966, and he purchased a small sailboat in 1970 and a fixed-keel boat in 1975 or 1976 for his personal use. On their 1986, 1987, and 1988 joint tax returns, petitioners jointly reported wages and net income from the practice of medicine in amounts ranging from approximately $166,000 to $230,000 per year. Against the income reported, petitioners claimed losses attributable to boating and residential rental activities. Petitioners reported boat chartering income and 2 Section references are to the Internal Revenue Code in effect for the years in issue. Rule references are to this Court's Rules of Practice and Procedure. 3 The parties' stipulations of facts and exhibits are incorporated by this reference.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011