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pursuant to section 469(a); and (2) whether petitioners are liable
for the accuracy-related penalty pursuant to section 6662(a).
All section references are to the Internal Revenue Code as in
effect for the year in issue. All Rule references are to the Tax
Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The
stipulation of facts and the attached exhibits are incorporated
herein by this reference.
At the time the petition was filed, George and Bozenna
Pohoski, husband and wife, resided in Camarillo, California.
Background
During 1993, Mr. Pohoski was employed as an engineer with the
U.S. Department of Defense, and Mrs. Pohoski was employed as a
nurse. Both petitioners worked an average of 40 hours per week.
Petitioners have two children.
Throughout the year in issue, petitioners owned two
condominiums in Camarillo, California (the Camarillo condominiums),
and two condominiums in Hawaii. The Camarillo condominiums were
generally rented out on a long-term lease basis. Petitioners
managed the Camarillo condominium properties themselves, collecting
the rents, making repairs, and maintaining the books and records.
Respondent concedes that the rental of the Camarillo condominiums
was properly reported by petitioners on their 1993 joint Federal
income tax return.
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