- 6 - deduction is carried forward and deductible in succeeding taxable years to the extent of net investment income in those years.3 Decision will be entered for respondent. 3 On their income tax return for 1999, petitioners also reported Schedule E income of $17,569 from two sources, the rental of a commercial building and an apartment partnership. Although petitioners, in their petition and at trial, did not allege or claim the $17,569 to be net investment income, the Court, nevertheless, after trial, ordered the parties to address this income item since, under sec. 163(d)(4)(B), "investment income", in part, includes gross income from "property held for investment", subject, however, to limitations under sec. 163(d)(5)(A)(ii). Based on the reports filed by the parties, the Court is not satisfied that the $17,569 in income is outside the realm of the limitations of sec. 163(d)(5)(A)(ii).Page: Previous 1 2 3 4 5 6
Last modified: May 25, 2011