Kanhua and Lihying Young - Page 2




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          indicated, all section references are to the Internal Revenue               
          Code in effect for the years in issue, and all Rule references              
          are to the Tax Court Rules of Practice and Procedure.                       
               The issues for decision are: (1) Whether petitioners                   
          properly reported amounts of rental income and deductions on                
          Schedule E of their 1994 and 1995 Federal income tax returns; (2)           
          whether petitioners are entitled to deduct S corporation losses             
          claimed on Schedule E of their 1994 and 1995 Federal income tax             
          returns; and (3) whether petitioners are liable for the accuracy-           
          related penalty pursuant to section 6662(a) for both years 1994             
          and 1995.  Petitioners filed a timely petition with this Court.             
          At the time of filing the petition, petitioners resided in                  
          Rockville, Maryland.                                                        
          Background                                                                  
               Petitioner Kanhua Young was employed as an economist by the            
          U.S. Department of Commerce during the years in issue.                      
          Petitioner Lihying Young (hereinafter petitioner) is also an                
          economist and the sole owner and president of OMNIX, an S                   
          corporation.  To the extent that OMNIX conducted any business               
          activity, such activity occurred at petitioners' home.                      
               Petitioners timely filed their 1994 and 1995 Federal income            
          tax returns.  Petitioners reported the following items of income            
          and expense on their Federal tax returns for the years in issue:            






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