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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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