George and Bozenna Pohoski - Page 2

                                        - 2 -                                         

          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.                                                          



Page:  Previous  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