- 2 - income from the calculation of passive loss for a sec. 469, I.R.C. activity, despite the proper grouping of such income with an item of passive loss against which such income would otherwise be offset. Murray H. Falk, for petitioners. Paul L. Dixon, for respondent. OPINION WELLS, Judge: Respondent determined deficiencies in petitioners’ Federal income taxes for 1999 and 2000 as follows:1 Year Deficiency 1999 $17,011 2000 114,443 1Although respondent initially determined corresponding deficiencies of $17,011 and $16,384 for 1999 and 2000, respectively, the parties have stipulated that the deficiency determined by respondent for 2000 is $14,443. The issue to be decided is whether losses from petitioners’ rental activity constitute passive activity losses pursuant to section 469.2 1Although respondent initially determined sec. 6662(a) accuracy-related penalties of $3,402.20 for 1999 and $3,276.80 for 2000, respondent concedes that penalties are inapplicable. 2All section references are to the Internal Revenue Code, as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011