- 5 -
records of the condominium association to be certain that
accounting principles were properly applied.
Petitioner attended eight board of directors meetings in
1991 and six in 1992.4 Petitioner also attended the 1991 and
1992 annual meetings of the council of unit owners in her
capacity as a board member. Because petitioner was the only
board member who resided in Montgomery County, Maryland, unit
owners living nearby often contacted petitioner in regard to
various matters concerning Wisp. In 1991, petitioner spent at
least 100 hours, but not more than 148 hours, on board-related
matters. In 1992, petitioner spent at least 90 hours, but not
more than 123 hours, on board-related matters.
On Schedules C of their 1991 and 1992 Federal income tax
returns, petitioners claimed net losses in the amounts of $12,723
and $9,765, respectively, from the condominium hotel activity.5
In her notice of deficiency, respondent determined that the
losses were passive activity losses within the meaning of section
469. Therefore, the losses were allowed only to the extent of
passive income.
4 In his capacity as a unit owner, petitioner Barry H.
Scheiner attended three such meetings in 1991 and two in 1992.
5 On the 1992 return, separate Schedules C were filed by
each petitioner reporting one-half the total loss.
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