T.C. Memo. 2001-111
UNITED STATES TAX COURT
OSAMA A. MOWAFI, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1663-00. Filed May 10, 2001.
Mark E. Kellogg, for petitioner.
Taylor Cortright, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Petitioner petitioned the Court to redetermine
deficiencies of $36,441 and $35,962 in his 1994 and 1995 Federal
income tax. We must decide whether petitioner is a real estate
professional under section 469(c)(7). We hold he is not. Unless
otherwise indicated, section references are to the Internal
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