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1. Whether petitioners are exempt from Federal income tax.
We hold that they are not.
2. Whether petitioners may deduct advertising expenses for
selling living trusts in 1991. We hold that they may not.
3. Whether petitioners may deduct expenses for selling
living trusts and food supplements and renting their Nebraska
Street property in 1991. We hold that they may deduct expenses
to the extent stated below.
4. Whether petitioners may deduct or capitalize for 1991
various expenses related to their Springs Road and Mesa Verde
rental property. We hold that petitioners may not deduct or
capitalize some of their expenses, may deduct other expenses, and
must capitalize the remaining expenses.
5. Whether petitioners may deduct points that they paid
in connection with certain loans in 1992. We hold that they may
not.
6. Whether petitioners' losses from their airplane leasing
activity are passive losses under section 469. We hold that they
are.
7. Whether petitioners are liable for the accuracy-related
penalty under section 6662(a) for 1991 and 1992. We hold that
they are not.
Section references are to the Internal Revenue Code in
effect for the years in issue. Rule references are to the Tax
Court Rules of Practice and Procedure.
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