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Respondent determined deficiencies of $9,845 and $3,846 in
petitioner's 1999 and 2000 Federal income taxes, respectively.
The issues for decision are: (1) Whether petitioner is
entitled to claim rental real estate losses in excess of those
allowed by respondent; (2) whether petitioner is entitled to
deductions for employee business expenses; and (3) whether
petitioner is liable for the 10-percent additional tax under
section 72(t) for early distributions from retirement plans.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the exhibits received into evidence
are incorporated herein by reference. At the time the petition
in this case was filed, petitioner resided in Sacramento,
California.
1. Petitioner's Rental Real Estate Losses
During the years in issue, petitioner owned three houses:
(1) 8501 Canterbury (Canterbury) in Sun Valley, California; (2)
960 N. Adams (Adams) in Chandler, Arizona; and (3) 28705
Persimmon Lane (Persimmon) in Saugus, California.
Petitioner purchased the Canterbury house around 1982 and
still owns it. He did not have a tenant in this house during
either 1999 or 2000.
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