- 2 -
Accuracy-Related
Year Deficiency Penalty
1994 $8,619 $934
1995 10,939 2,188
The issues remaining for decision are:
(1) Are petitioners entitled for each of the years at issue
to deduct under section 212 certain expenditures that they made
during each of those years with respect to certain real property
that they owned? We hold that they are not.
(2) Are petitioners liable for each of the years at issue
for the accuracy-related penalty under section 6662(a)? We hold
that they are.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time the petition was filed, Alton M. Towles (Mr.
Towles) resided in Florida.
Around March 1991, Barbara D. Towles (Ms. Towles), who died
on August 19, 1997, and her husband Mr. Towles acquired certain
real property located at 18 Paradise Lane, Treasure Island,
Florida (Paradise Lane property), which was zoned as a multi-
family property. Located on that property at that time was a
two-story building consisting of about 6,250 square feet that was
configured as six apartment units, all of which were being leased
1(...continued)
Tax Court Rules of Practice and Procedure.
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Last modified: May 25, 2011