- 2 -
Respondent determined deficiencies in petitioners' Federal
income taxes of $19,336 and $26,084, respectively, for 1996 and
1997 and the accuracy-related penalty under section 6662(a) for
1997 in the amount of $5,216.80. At trial, petitioners conceded
a charitable contributions adjustment for the year 1996. The
issues for decision are: (1) Whether the passive loss rules of
section 469 preclude petitioners from deducting real estate
rental losses of $128,168 for 1996 and $95,553 for 1997, and (2)
whether petitioners are liable for the accuracy-related penalty
under section 6662(a) for 1997.
Some of the facts were stipulated. Those facts, with the
annexed exhibits, are so found and are made part hereof.
Petitioners’ legal residence at the time the petition was filed
was Pasadena, California.
Petitioners Karl (Mr. Jahina) and Birgit Jahina (Mrs.
Jahina) were married during the years at issue. They owned real
estate rental property consisting of five apartment buildings and
three single-family condominiums during the years at issue.
These properties are collectively referred to as the rental
properties. The apartment buildings included the Hermitage
Property, with 14 units; Coldwater Property, 19 units; Santa
Anita Property, 22 units; Moorpark Property, 29 units; and
Buffalo Property, 25 units. All of these properties were located
in the Los Angeles area.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011