- 2 - Respondent determined deficiencies in, and an addition to, petitioners’ Federal income taxes for the taxable years 1996 and 1997 as follows: Addition to tax Year Deficiency Sec. 6651(a)(1) 1996 $10,385 $200 1997 6,878 --- After petitioners’ concessions,2 the issue for decision is whether petitioner Richard B. May (petitioner) elected under section 469(c)(7)(A) to treat his various rental real estate activities as a single activity for the years in issue. We hold that he did not. An adjustment to the amount of petitioners’ itemized deductions for each of the years in issue is a purely computational matter, the resolution of which is dependent on our disposition of the disputed issue. Background Some of the facts have been stipulated, and they are so found. We incorporate by reference the parties’ stipulation of facts, supplemental stipulation of facts, and accompanying exhibits. 2 Petitioners concede: (1) They are not entitled to claim the dependency exemption deductions disallowed by respondent in the notice of deficiency, and (2) they are liable for the addition to tax for failure to timely file their Federal income tax return for 1996.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011