- 2 - All section references are to the Internal Revenue Code in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated. All dollar amounts are rounded to the nearest dollar, unless otherwise indicated. References to petitioner are to Stephanya M. Barranti. After concessions,1 the issues for decision are: (1) Whether petitioners are entitled to deduct the $5,852 loss sustained in renting the property to petitioner's brother and the loss realized on the sale of petitioner's residential property. We hold they are not. (2) Whether petitioners are liable for an accuracy-related penalty pursuant to section 6662(a). We hold they are. Some of the facts have been stipulated and are so found. The stipulated facts and the accompanying exhibits are incorporated herein by this reference. At the time the petition in this case was filed, petitioners resided in Alamo, California. FINDINGS OF FACT On February 21, 1991, petitioner acquired by gift a joint tenancy in her grandmother's house located in San Mateo, 1Before trial, respondent conceded that petitioners are entitled to deduct depreciation expense of $19,936, and $44,369 of the $65,187 expenses reported on Schedule C that were disallowed in the notice of deficiency. Petitioners conceded that they are not entitled to deduct $20,818 of the expenses they claimed on Schedule C and that they understated dividend income by $1,724 on their return for 1993.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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