James R. & Anita Madler - Page 2

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            181, and 182.1  Respondent determined deficiencies in                                       
            petitioners' Federal income taxes as follows:                                               
                                        Year        Amount                                              
                                        1991        $3,029                                              
                                        1992           676                                              
                                        1993           296                                              
            After concessions,2 the only issue remaining for decision is                                
            whether petitioners qualify for the $25,000 offset for rental                               
            real estate activities under section 469(i) for the taxable years                           
            1991, 1992, and 1993.                                                                       
                  The facts have been fully stipulated.  The stipulation of                             
            facts and the attached exhibits are incorporated herein by this                             
            reference.  At the time of filing the petition, petitioners                                 
            resided at Chicago, Illinois.                                                               
                  During the years in issue, petitioner James Madler                                    
            (hereinafter sometimes referred to as petitioner) was self-                                 
            employed as an attorney, and petitioner Anita Madler was not                                


            1  All section references are to the Internal Revenue Code                                  
            in effect during the years in issue, unless otherwise indicated.                            
            All Rule references are to the Tax Court Rules of Practice and                              
            Procedure.                                                                                  
            2  Petitioners have conceded:  (1) They failed to report                                    
            income in the amount of $3,478 on their 1991 return; (2) they                               
            failed to report wages in the amount of $571 on their 1991                                  
            return; (3) they failed to report income in the amount of $350 on                           
            their 1993 return; and (4) they are not entitled to claim                                   
            deductions for the taxable years 1991 through 1993 resulting from                           
            losses attributable to property they owned in Cloudcroft, New                               
            Mexico.  The remaining adjustments are computational and are                                
            dependent upon our resolution of the issue for decision.                                    




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