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Background
This case was submitted fully stipulated under Rule 122.
The stipulation of facts and attached exhibits are incorporated
herein by this reference and found accordingly.
Petitioner is an individual residing, at the time the
petition in this case was filed, in Virginia Beach, Virginia.
The returns for the periods here involved were filed with the
Internal Revenue Service at Norfolk, Virginia. Petitioner's
individual return for the taxable year 1988 was filed
delinquently on July 24, 1991. Petitioner's individual return
for the taxable year 1989 was filed delinquently on January 16,
1992.
Petitioner was general partner of the Pilot House Associates
II partnership (Associates). Associates built the Pilot House
condominium project (Project), and the condominium units were
owned by Associates until sold. Associates constituted, for
purposes of section 469, a nonpassive activity of petitioner for
the taxable years 1988 and 1989. Associates reported the
following gross receipts and cost of goods sold for the years at
issue.
1988 1989
Gross receipts $469,281 $297,239
Cost of goods sold 477,473 302,000
Gross income $(8,192) $ (4,761)
Petitioner's shares of Associates' nonpassive losses were as
follows:
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