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Respondent determined a deficiency in petitioner's 1991
Federal income tax in the amount of $3,181.
The issue for decision is whether the deductions petitioner
claimed on a Schedule E filed with his 1991 Federal income tax
return are subject to the limitation imposed by section
280A(c)(5).
Background
Some of the facts have been stipulated, and they are so
found. At the time that the petition was filed in this case,
petitioner resided in Beijing, China.
In 1987 petitioner purchased and began to use as his
principal residence a house in San Bruno, California (the San
Bruno residence). The San Bruno residence is a two-story house
containing four bedrooms (including a master bedroom that has an
outside entrance and a private bathroom), two bathrooms
(including the one attached to the master bedroom), a living
room, a dining room, a kitchen, a laundry room, storage space,
and an attached two-car garage.
Petitioner holds degrees in mathematics and computer
science. In 1990 he started working for the Qume Corp. (Qume).
Shortly thereafter, Qume began to experience financial
difficulties. Because he was concerned about his job security
with Qume and to supplement his income, in November 1990
petitioner rented out one bedroom of the San Bruno residence to
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