Umit Tarakci - Page 2




                                        - 2 -                                         
          accuracy-related penalty under section 6662(a) in the amount of             
          $5,785.60.2                                                                 
               After concessions, the issues for decision3 are:  (1)                  
          Whether petitioner’s leasing activity was a trade or business;              
          (2) whether petitioner’s losses constitute nondeductible passive            
          losses under section 469; (3) whether petitioner substantiated              
          deductions claimed on his Schedule C, Profit or Loss From                   
          Business; (4) whether petitioner is liable for an addition to tax           
          for failing to timely file his 1993 Federal income tax return;              
          and (5) whether petitioner is liable for the accuracy-related               
          penalty under section 6662(a).                                              
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the accompanying exhibits are                  
          incorporated herein by this reference.  Petitioner is a cash                
          method taxpayer who resided in Fall City, Washington, at the time           
          he filed his petition.                                                      
               Petitioner is a scientist with an M.S. degree in solid state           
          devices and a Ph.D. degree in ultrasonic and semiconductor device           



               2All subsequent references to monetary amounts are rounded             
          to the nearest dollar.                                                      
               3The notice of deficiency contains adjustments to                      
          petitioner’s itemized deductions and statutory exemption                    
          allowance for the year in issue.  These are computational                   
          adjustments which will be resolved by the outcome of the issues             
          to be decided, and we do not separately address them.                       





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011