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Respondent determined deficiencies in petitioners' Federal
income taxes for 1991, 1992, and 1993 in the amounts of $2,548,
$2,772, and $2,774, respectively.
The issue for decision is whether petitioners' claimed
Schedule C losses for 1991, 1992, and 1993 constitute passive
activity losses under section 469. The resolution of this issue
turns on whether petitioners materially participated in the
activity of renting their condominium unit during the taxable
years in issue.
Some of the facts have been stipulated and are so found.
The stipulations of fact and attached exhibits are incorporated
herein by this reference. Petitioners resided in Roseville,
Minnesota, on the date the petition was filed in this case.
Petitioner husband works as a manager of a commercial unit
for Norwest Banks. His formal education includes a bachelor's
degree from the University of Minnesota and a master's degree
from Mankato University.
In 1988, petitioners purchased condominium unit number 6
(the unit) at Bluefin Bay, a condominium complex located in
Tofte, Minnesota. Tofte is located on the shore of Lake Superior
in Superior National Forest, approximately 225 miles northeast of
petitioners' residence.
1(...continued)
issue. All Rule references are to the Tax Court Rules of
Practice and Procedure.
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