Ronald I. and Lois B. Koenig - Page 15

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          Issue 3.  Net Loss for Rental Real Property                                 
               Respondent determined that petitioners' net loss for rental            
          real property in 1990 is limited to $25,000.  Petitioners assert            
          that they are not limited by the $25,000 rental loss allowance              
          and that they are entitled to deduct $57,975, the full amount of            
          their loss.                                                                 
               During 1990, petitioners owned five separate parcels of                
          rental real property.  Four of the properties were located in               
          Scottsdale, Arizona (the Scottsdale properties), and one was                
          located in Sumner, Washington (the Sumner property).  The                   
          Scottsdale properties, which comprised two townhomes and two                
          condominiums, were upscale, resort-oriented properties with                 
          numerous amenities.  The Sumner property was a lakefront single-            
          family dwelling with an unobstructed view of Mt. Rainier.                   
               Lois B. Koenig (Mrs. Koenig) personally conducted the                  
          leasing activities for the Sumner property.  Petitioners engaged            
          Racquet Club Realty to act as a rental broker to locate tenants             
          for the Scottsdale properties.                                              
               Mrs. Koenig was responsible for the management, maintenance,           
          and operation of the rental properties.  Her responsibilities               
          included collecting rents and arranging for necessary repairs.              
          In addition, when tenants moved out, it was necessary to clean              
          and sometimes paint the rental properties before new tenants                







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