Andrew Wesley Frank & Joy Mary Frank - Page 2

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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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