- 2 -
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.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011