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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
6662(a).
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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