-2-
1997 (the relevant years).2 We hold that petitioners operated
their jet charter activity for profit during each of the relevant
years.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the accompanying exhibits are
incorporated by this reference. Petitioner Leonard Rabinowitz
(Mr. Rabinowitz) resided in Beverly Hills, California, and
petitioner M. Carole Rabinowitz, also known as Carole Little (Ms.
Little) resided in Los Angeles, California, at the time
petitioners filed the petition in this case.
Petitioners
Mr. Rabinowitz began his sales career with a job at his
father’s company while still in high school selling paint,
plastic, and tools to automotive repair shops. After high
school, he continued working for his father’s company and then
2The “relevant years” in this case include 1995 and 1996,
which are not years for which respondent issued a notice of
deficiency. To determine the correct tax liability for 1992 and
1993, however, the correct net operating loss carrybacks must be
computed, which requires us to determine whether petitioners
operated the jet charter activity for profit in 1995 and 1996.
Sec. 6214(b) obligates us to consider facts for other years as
may be necessary to redetermine the amount of the deficiencies
for the deficiency years. Sec. 6214(b); Hill v. Commissioner, 95
T.C. 437, 439-440 (1990). Therefore, we consider whether
petitioners operated the jet charter activity for profit in 1995
and 1996 solely to permit the parties to compute the correct net
operating loss carrybacks for 1992 and 1993 pursuant to Rule 155.
See sec. 6214(b); Hill v. Commissioner, supra at 439-440.
Although respondent issued a notice of deficiency to petitioners
for 1992, respondent did not assert in the notice of deficiency
that petitioners did not operate the jet charter activity for
profit in that year. We therefore do not consider whether the
activity was operated for profit during 1992.
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