T.C. Memo. 2005-14
UNITED STATES TAX COURT
ASSAF F. AL ASSAF AND REHAB ASSAF, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 770-03. Filed January 31, 2005.
Rehab R. Assaf, for petitioners.
William F. Castor, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
KROUPA, Judge: Respondent determined deficiencies of $8,940
for 1999 and $12,486 for 2000 in petitioners’ Federal income
taxes. The issue to be decided is whether the passive loss rules
of section 4691 preclude petitioners from deducting leasing
1All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
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