General K. Hilliard and Ida M. Hilliard - Page 21

          Commissioner, 949 F.2d at 352; Golanty v. Commissioner, 72 T.C.             
          at 426-427.  Petitioners generated substantial losses from their            
          rental activity, mostly from depreciation, and were able to                 
          shelter their medical income with the losses.                               
              (8) The financial status of the taxpayer.  Because of                  
          petitioners' income from their medical practices, they obtained             
          significant tax benefit from the rental activity losses.                    
               (9) The presence of elements of personal pleasure or                   
          recreation.  Mr. Hilliard went to the property occasionally to do           
          repairs; however, petitioners used the property for personal                
          trips and recreational purposes.                                            
               We hold that petitioners' Tahoe rental activity was not                
          engaged in for profit within the meaning of section 183(c).                 


          V.  Automobile Expenses                                                     
               During the years in issue, petitioners owned four                      
          automobiles.  Mrs. Hilliard drove the Mercedes, which was used to           
          commute to work, to drive between different work locations, and             
          for personal errands.  Her offices were in Oakland, California,             
          for all of the years in issue and in San Ramon, California, for 3           
          months during 1986.  The commute from Mrs. Hilliard's residence             
          to her office was 8 to 9 miles, and the distance between the San            
          Ramon and Oakland offices was 15 miles.  Mrs. Hilliard made early           
          morning rounds in two hospitals:  one which was about 3 miles               
          from her Oakland office, and the other was less than 1 mile from            
          her Oakland office.  The majority of her patients were at the               




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