- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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