Ronald I. and Lois B. Koenig - Page 2

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               All section references are to the Internal Revenue Code in             
          effect for the taxable years in issue, and all Rule references              
          are to the Tax Court Rules of Practice and Procedure, unless                
          otherwise indicated.  References to petitioner are to Ronald I.             
          Koenig.                                                                     
               After concessions,1 the issues for decision are:  (1)                  
          Whether for 1990 petitioners are entitled to a business bad debt            
          deduction relating to their disposition of the Washington                   
          Chocolate Co. (Washington Chocolate).  We hold they are not.  (2)           
          Whether for 1990 petitioners are entitled to deductions for                 
          activities involving ancient artifacts.  This turns on whether              
          petitioners were actively engaged in a trade or business during             
          1990.  We hold petitioners were not engaged in a trade or                   
          business during 1990 and are not entitled to the deductions.  (3)           
          Whether for 1990 petitioners' net loss for their rental real                
          estate activity is limited to $25,000.  We hold it is.  (4)                 
          Whether for 1990 petitioners are liable for an addition to tax              
          pursuant to section 6651(a)(1) for delinquent filing of a return.           
          We hold they are.  (5) Whether for 1990 petitioners are liable              
          for a penalty pursuant to section 6662(a) for negligence or                 
          disregard of rules or regulations.  We hold they are not.                   



               1    The parties settled all issues relating to taxable year           
          1991 before trial.                                                          




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