- 3 - 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:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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