Arnold P. Mordkin and Cindy Mordkin - Page 2

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               The issues remaining for decision are:                                 
               (1) Is the loss at issue for each of the years 1989 and                
          1990 a passive activity loss within the meaning of section 469?             
          We hold that it is.                                                         
               (2) Are petitioners liable for each of the years 1989 and              
          1990 for the addition to tax under section 6651(a)?  We hold that           
          they are.                                                                   
               (3) Are petitioners liable for each of the years 1989 and              
          1990 for the accuracy-related penalty under section 6662(a)?  We            
          hold that they are.                                                         
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
               Petitioners resided in Newport Beach, California, at the               
          time the petition was filed.  They filed joint Federal income tax           
          returns for the years 1989 and 1990.                                        
               Petitioner Arnold P. Mordkin2 is an attorney who was ad-               
          mitted to practice law in California in 1963 and who specialized            
          during all relevant periods in personal injury and medical                  
          malpractice matters.  During the years at issue, petitioner, who            
          resided in California, practiced law on a full-time basis as an             
          employee of Arnold P. Mordkin, Inc. (Mordkin, Inc.), a profes-              
          sional corporation located in California, and Mordkin, Inc. was a           
          stockholder of Bridgman, Mordkin, Gould & Shapiro, Inc., a                  

          2  References to petitioner in the singular are to petitioner               
          Arnold P. Mordkin.                                                          



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