Jefferry Phuong Vo and Mai Xuan Nguyen - Page 3




                                        - 2 -                                         
          1995 Federal income tax and an accuracy-related penalty under               
          section 6662 of $1,145 for taxable year 1995.                               
               The issues for decision are:  (1) Whether petitioners were             
          engaged in a trade or business or an activity for the production            
          of income during the year in issue; (2) if so, whether                      
          petitioners’ claimed expenses are ordinary and necessary; and (3)           
          whether petitioners are liable for negligence penalties pursuant            
          to section 6662.                                                            
                                     Background                                       
               The stipulation of facts and the accompanying exhibits are             
          incorporated herein by reference.  Petitioners resided in                   
          Portland, Oregon, at the time the petition in this case was                 
          filed.                                                                      
               Petitioners were husband and wife in 1995 and filed a joint            
          Federal income tax return for the taxable year.  Petitioner                 
          Jefferry Phuong Vo (petitioner), along with two friends, formed a           
          partnership and designed a system in 1992 to use solar energy to            
          generate electricity to run household appliances.  They rented a            
          three bedroom residential property located at 1770 Caloosa Court,           
          San Jose, California (San Jose property), in which to develop and           
          apply the solar-powered electric generator (generator).                     
          Petitioners claim that they needed a large unobstructed yard with           
          sufficient sunlight to meet their solar needs and that the                  
          residential property was less expensive than a commercial                   






Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011