T.C. Memo. 2001-296
UNITED STATES TAX COURT
BRUCE AND JUDY BAILEY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3293-00. Filed November 7, 2001.
Bruce and Judy Bailey, pro se.
Christine V. Olsen, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: Respondent determined deficiencies of $12,094
and $11,651 in petitioners’ Federal income tax for 1996 and 1997,
respectively. After concessions, the remaining issues for
decision are: (1) Whether petitioner Judy Bailey (petitioner)
was a real estate professional under section 469(c)(7) during
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