- 9 - losses in the amount of $74,763. The notice of deficiency does not explain how this adjustment was computed or why it is $413 more than the deduction claimed with respect to the Cloudia. The amount of the adjustment appears to be the difference between the aggregate amount deducted on Schedule E, $78,751, and the current year loss with respect to the property at 1813-15 NW 12th, $3,988. Thus, it appears that in computing the adjustment respondent disallowed a current loss with respect to the property at 2709 NW 12th in the amount of $113 and disallowed losses accumulated from prior years with respect to the properties at 1813-15 NW 22d and 1809 Carey Place in the amount of $617 and $1,172, respectively. OPINION The principal issue in this case involves respondent's disallowance of $74,763 of the deductions claimed by petitioner on the Schedule E, Supplemental Income and Loss, filed as part of petitioner's 1990 return. Petitioner argues that this amount is deductible under section 212(1) or (2). The premise of petitioner's argument is that the entire amount of the adjustment is attributable to "Petitioner's conduct of the Cloudia activity". However, according to petitioner's 1990 return, after applying the passive loss limitation rules of section 469, petitionerPage: 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