Steven Carl Akerson - Page 6

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            his taxable years 1988 through 1992, he described his principal                              
            business as “hotel resort”; for his taxable years 1993 through                               
            1995, he described his principal business activity as “hotel                                 
            resort, solar electronics manufacture & sale”.  He reported gross                            
            income and expenses as follows:                                                              
                  Year        Gross Income             Expenses           Net Gain/Loss                  
                  1988        $0                       $14,642            $(14,642)                      
                  1989               0                 34,049             (34,049)                       
                  1990               0                 82,792             (82,792)                       
                  1991               339               70,703             (70,364)                       
                  1992        8,420                    61,883             (53,463)                       
                  1993        15,368                   94,508             (79,140)                       
                  1994        160,204                  113,235            46,969                         
                  1995        109,799                  99,569             10,230                         
            For those years, petitioner's gross income is broken down further                            
            as follows:                                                                                  
                             Total              Gross Income      Gross Income                          
                  Year        Gross Income       from Resort       from Solar Sales                      
                  1988        $0                 $0                $0                                    
                  1989        0                        0                        0                        
                  1990               0                 0                        0                        
                  1991               339         339                            0                        
                  1992        10,977             6,424                    4,553                          
                  1993        16,021             11,891                   4,130                          
                  1994        160,365            10,375            149,990                               
                  1995        164,487            6,211             158,276                               

                                                OPINION                                                  
            I.  Deficiencies                                                                             
                  A.  Section 183--For-Profit Requirement                                                
                  Section 183(a) provides:  "In the case of an activity                                  
            engaged in by an individual or an S corporation, if such activity                            
            is not engaged in for profit, no deduction attributable to such                              
            activity shall be allowed under this chapter except as provided                              




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