- 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 commercialPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011