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The decision to be entered is not reviewable by any other court,
and this opinion should not be cited as authority.
Respondent determined deficiencies in petitioner's Federal
income taxes of $4,256, $6,858, and $16,977 for 1992, 1993, and
1994, respectively. The issues for decision are whether
petitioner: (a) Was in the trade or business of lending money;
(b) and if so, is entitled to deductions for business expenses,
business bad debts, and the net operating losses therefrom; and
(c) is entitled to deduct real estate rental losses in excess of
$25,000. Our resolution of these issues will determine the
computational issue of whether petitioner is entitled to credit
for the elderly or disabled under section 22 in 1992 or 1993.
Background
The stipulation of facts and the accompanying exhibits are
incorporated herein by reference. Petitioner resided in
Rockville, Maryland, at the time his petition was filed in this
case.
Since 1971 petitioner has been employed as an associate
professor of chemistry at the University of the District of
Columbia (UDC). Petitioner was generally engaged in his
professorial duties from the middle of August through the middle
of May. In some years, petitioner taught evening classes and in
others, day classes. Because of the lack of a graduate chemistry
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