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whether petitioner is entitled to head-of-household filing status
in 1998 and 1999; and (4) whether petitioner is entitled to
various Schedule C, Profit or Loss From Business, deductions in
1998 and 1999.
An adjustment to the amount of petitioner’s itemized
deductions is purely a mechanical matter, the resolution of which
is dependent on our disposition of the issues for decision.
I. Background
Some of the facts have been stipulated, and they are so
found. We incorporate by reference the parties’ stipulation of
facts and accompanying exhibits.
At the time that the petition was filed, petitioner resided
in Thousand Oaks, California.
A. Petitioner’s Occupation
Until the real estate market crash in California in 1997,
petitioner worked full time as a real estate agent in
Victorville, California. In mid-1997, petitioner relocated to
Thousand Oaks to find a better job, and he started working full
time as a real estate agent for Fred Sands Brown Realty (Fred
Sands). By 1998, petitioner was working only part time at Fred
Sands during the evenings and on the weekends. At all relevant
times, petitioner maintained an office at Fred Sands and focused
his real estate activity on listings and investors in both
Victorville and Thousand Oaks. Victorville is located
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