- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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