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be entered is not reviewable by any other court, and this opinion
should not be cited as authority.
Respondent determined deficiencies in petitioners' Federal
income tax of $17,656 for 1996 and $19,849 for 1997. The issue
for decision is whether petitioners' business losses constitute
passive activity losses. The amount of petitioners' allowable
itemized deductions and personal exemptions will be determined by
our disposition of the contested issue.
The stipulated facts and exhibits received into evidence are
incorporated herein by reference. At the time the petition in
this case was filed, petitioners resided in Moatsville, West
Virginia.
Background
Petitioners' Vocations
During the years 1996 and 1997, petitioners resided in
Trappe, Pennsylvania, and both were full-time employees at a
large computer software corporation, the Oracle Corporation
(Oracle). Petitioner Susan Truskowsky was a program manager in
the Program Management Group at Oracle Consulting. Her job
required her to travel to projects around the country, mostly in
the Mid-Atlantic region and to Dallas, Texas. In 1996,
petitioner Thomas Truskowsky was employed as senior principal
consultant for Oracle. In 1997 he became a technical manager.
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