- 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