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under sections 6651(a)1 and 6654(a) in the amounts of $39,035 and
$6,806, respectively.
After concessions, the issues for decision are: (1) Whether
for 1992 petitioner is entitled to deduct 50 percent of the
substantiated expenses incurred for certain rental real estate.
This turns on whether petitioner's rental real estate activities
were conducted as a partnership. We hold that petitioner's
rental real estate activities were conducted as a partnership,
and he is entitled to deduct 50 percent of the expenses incurred.
(2) Whether for 1992 petitioner is liable for an addition to tax
pursuant to section 6651(a). We hold he is. (3) Whether for
1992 petitioner is liable for an addition to tax pursuant to
section 6654(a). We hold he is.
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, petitioner resided in Portland, Oregon.
Background
In April 1987, petitioner acquired a 50-percent interest in
real property located at 208 Oak Street in Ashland, Oregon (208
1 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.
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