- 2 - Victor A. Kornis, for petitioners. Christa A. Gruber, for respondent. OPINION LARO, Judge: This case is before the Court on cross-motions for summary judgment. Respondent determined a $28,184 deficiency in petitioner's 1994 Federal income tax and a $5,637 accuracy- related penalty under section 6662(a). Petitioner, while residing in Greendale, Wisconsin, petitioned the Court to redetermine respondent’s determination. Following respondent’s concession that petitioner is not liable for the accuracy-related penalty, we must decide whether petitioner may offset the income and loss that he realized on his separate rental activities.1 We hold he may not. Unless otherwise stated, section references are to the Internal Revenue Code applicable to 1994. Rule references are to the Tax Court Rules of Practice and Procedure. We refer to Thomas P. Krukowski as the sole petitioner. Background Petitioner is the president and sole shareholder of two subchapter C corporations. One corporation (the health club) 1 Petitioner asserts that he treated the separate rental activities as a single activity under sec. 1.469-4(c)(1), Income Tax Regs. The record does not support this assertion. To the contrary, the record reveals that petitioner treated his rental activities as separate activities.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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