- 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
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