T.C. Memo. 1998-17
UNITED STATES TAX COURT
GEORGE AND BOZENNA POHOSKI, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9027-96. Filed January 13, 1998.
Philip Garrett Panitz, for petitioners.
Donna F. Herbert, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge: Respondent determined a $28,143 deficiency in
petitioners' 1993 Federal income tax, and an accuracy-related
penalty of $2,662 pursuant to section 6662(a).
After concessions, we must decide: (1) Whether petitioners
materially participated in the rental of their two Hawaiian
condominiums for purposes of the passive activity loss rules
Page: 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