- 2 - Respondent determined a deficiency of $5,331 in petitioners' Federal income tax for 1991. The issues for decision are: (1) Whether petitioners were engaged in a trade or business activity within the intent and meaning of section 162(a) and, (2) if petitioners were not engaged in a trade or business activity under section 162(a), whether some or all of the expenses claimed as trade or business expenses are otherwise deductible under section 212(1) and (2) as expenses paid or incurred for the production or collection of income or for the management, conservation, or maintenance of property held for the production of income. Some of the facts were stipulated, and those facts, with the annexed exhibits are so found and are incorporated herein by reference. At the time the petition was filed, petitioners' legal residence was Fort Washington, Maryland. Harry E. Thomason (petitioner) and Hattie D. Thomason (Mrs. Thomason) were married in 1947, and, during the following year, petitioner became employed as a patent examiner by the U.S. Patent Office in Washington, D.C. In 1949, petitioner and Mrs. Thomason bought a parcel of real estate in Prince George's County, Maryland, and began building several rental houses there over a period of years. The houses were built substantially by 1(...continued) estate of the deceased petitioner. Rule 63.Page: 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