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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.
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