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Rule references are to the Tax Court Rules of Practice and
Procedure.
After concessions the remaining issues are whether
petitioner: (1) May deduct certain expenses relating to his
residential real estate, (2) has net operating losses to offset a
portion of his 1994 taxable income, (3) is allowed a depreciation
deduction for property purportedly used in his trade or business,
and (4) is liable for a section 6662(a) penalty relating to
negligence.
FINDINGS OF FACT
Petitioner resided in San Antonio, Texas, at the time he
filed his petition.
During the year in issue, petitioner was married to Bobbie
J. Sandoval; was the sole proprietor of Allied Electric and Air
Conditioning Co. (Allied Electric), an electric and air
conditioning business; and was the owner of real estate in San
Antonio located at 4330 Seabrook Drive (Seabrook), 320 Indiana
(Indiana), and a duplex at 137 and 139 El Monte Boulevard (El
Monte). Seabrook, Indiana, and El Monte were purchased in 1979,
1987, and 1988, respectively.
On petitioner’s 1994 Federal income tax return, received by
respondent on October 19, 1995, he omitted his rental activities,
incorrectly claimed single filing status, and did not review the
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