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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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