Gerald L. and Joy M. Zeidler - Page 3

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          whether petitioners have established basis under section 167(c)             
          as to one of the rental properties for purposes of determining              
          the allowable depreciation deduction for each of the years at               
          issue; (6) whether section 280F(d)(4) precludes petitioners from            
          claiming depreciation on a computer and peripheral equipment                
          located in their home that was used in petitioners' trade or                
          business activity and in petitioners' rental activity;                      
          (7) whether petitioners are entitled to a deduction, under                  
          section 162(a), for travel expenses attributable to petitioner              
          Joy M. Zeidler (Mrs. Zeidler), who accompanied her husband,                 
          petitioner Gerald L. Zeidler (Mr. Zeidler), on two business                 
          trips; and (8) whether petitioners are liable for the additions             
          to tax under section 6651(a)(1) and penalties under section                 
               Some of the facts have been stipulated, and those facts,               
          with the annexed exhibits, are so found and are incorporated                
          herein by reference.  Petitioners, husband and wife, were legal             
          residents of Greendale, Wisconsin, at the time their petitions              
          were filed.                                                                 
               During the 3 years at issue, Mr. Zeidler was employed as a             
          production manager at Ladish Co., Inc. (Ladish), at Cudahy,                 
          Wisconsin.  Ladish was in the foundry business, forging iron and            
          steel products.  Mr. Zeidler held college degrees in electrical             
          and chemical engineering.  Mrs. Zeidler was also employed at                

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