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Respondent determined a deficiency in petitioners' Federal
income tax for 1992 in the amount of $4,607 and an accuracy-
related penalty pursuant to section 6662(a) in the amount of
$921.
After concessions by the parties, the issues remaining for
decision are: (1) Whether petitioners are entitled to Schedule C
business expense deductions attributable to petitioner husband's
real estate activity in excess of amounts allowed by respondent;
(2) whether petitioners are entitled to an investment tax credit;
and (3) whether petitioners are liable for the section 6662(a)
accuracy-related penalty.2
Some of the facts have been stipulated and are so found.
The stipulations of fact and attached exhibits are incorporated
herein by this reference. Petitioners resided in Rosemount,
Minnesota, on the date the petition was filed in this case. All
references to petitioner in the singular are to Robert C. Fors.
Petitioner works as a real estate salesman. During 1992,
petitioner wife worked as a computer lab clerk at a school in
Rosemount, Minnesota.
1(...continued)
Practice and Procedure.
2 Respondent's adjustments to petitioners' liability for
self-employment taxes, deduction for one-half of such liability,
and earned income credit are computational and will be resolved
by the Court's holdings on the issues in this case.
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Last modified: May 25, 2011