- 2 - Respondent determined a deficiency in petitioner’s Federal income tax of $40,818, and an accuracy-related penalty of $7,683.20, for the taxable year 1998. The issues for decision are: (1) With respect to petitioner’s rental activities, whether the losses petitioner incurred are subject to the passive activity loss limitations of section 469; (2) with respect to petitioner’s business activities, (a) whether petitioner received unreported income as determined by respondent, and (b) whether petitioner is entitled to a business expense deduction disallowed by respondent; and (3) whether petitioner is liable for the accuracy-related penalty under section 6662(a). The adjustments in the notice of deficiency to the itemized deductions and to the self-employment income tax and the deduction therefor are computational and will be resolved by the Court’s holding on the issues. Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. Petitioner resided in San Diego, California, on the date the petition was filed in this case. Petitioner filed a Federal income tax return for taxable year 1998 with the filing status of head of household. Petitioner reported $300 of interest income, a $6,760 business loss, and a $62,297 loss from rental activities, for an adjustedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011