- 2 - Respondent determined a $26,693 deficiency in petitioners’ 2000 Federal income tax and a $5,338.60 penalty pursuant to section 6662(a). The issues for decision are: (1) Whether the passive activity rules of section 469 preclude petitioners from deducting losses from their rental real estate activities in the taxable year 2000, and (2) whether petitioners are liable under section 6662(a) for an accuracy-related penalty. Some of the facts have been stipulated, and they are so found. The stipulation of facts, supplemental stipulation of facts, and attached exhibits, as well as additional exhibits admitted during trial, are incorporated herein by this reference. Petitioners Susan Hanna (Mrs. Hanna) and Edward Hanna (Mr. Hanna) are married and resided in Sanibel, Florida, when they filed their petition. For convenience, we combine our findings and discussion herein. Sanibel is a popular vacation spot located on an island off the west coast of Florida. In 1999, petitioners purchased two houses in Sanibel and began renting them to vacationers. In 2000, petitioners rented the first house for a total of 20 weeks and the second house for a total of 19 weeks. Petitioners also purchased a third house in Sanibel in May 2000, which they immediately leased back to the sellers for the remainder of that year. For convenience, we refer to the management and operation of the three properties as the “rental activities”. Petitioners did not live in Sanibel in 2000. Instead, theyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011