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Respondent determined a deficiency of $3,074 in petitioner’s
1996 Federal income tax. The issue for decision is whether
petitioner is entitled to a deduction for a rental real estate
loss claimed on the Schedule E, Supplemental Income and Loss,
included with his 1996 Federal income tax return. The resolution
of this issue depends upon the amount of time that petitioner
spent performing services in connection with his rental real
estate activity during 1996.
Background
Some of the facts have been stipulated and are so found. At
the time that the petition was filed, petitioner resided in
Columbus, Ohio. Petitioner was married as of the close of 1996
and lived with his spouse at least for a portion of that year.
He filed a timely 1996 Federal income tax return as a married
individual filing separately.
Petitioner has been employed with the Ohio Department of
Taxation (the Department) since 1988. During 1996, petitioner
held a supervisory position at the Department. Not counting
vacation and sick leave, he worked 1,834 hours for the Department
that year.1
Over the years, petitioner purchased, and as necessary
renovated, residential real estate properties that he held for
1 Petitioner’s compensation from the Department was based on
a 2,080 hour work year.
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