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purported rental real properties for 1992 and 1993 and, if so, in
what amounts;
(3) whether petitioners are entitled under section 162 or
212(2) to deduct on Schedule E, Supplemental Income and Loss,
expenses with respect to their two purported rental properties
for 1992 and 1993 and, if so, in what amounts;
(4) whether petitioners are entitled to deduct under section
172 certain net operating losses they had computed with respect
to 1990 and 1991 and carried forward to 1992 and 1993 and, if so,
in what amounts;
(5) whether petitioners are liable under section 6662(a) and
(b)(1) for accuracy-related penalties for negligence for 1992 and
1993.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts, first supplemental stipulation of
facts, and second supplemental stipulation of facts are
incorporated herein by this reference.
Petitioners, who filed joint Federal income tax returns for
1992 and 1993, resided in Los Angeles, California, when they
filed their petitions in this case.
Background
On or about September 22, 1980, Oliver W. Wilson
(petitioner) and his brother, Fred L. Wilson (Fred), purchased
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