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Respondent determined for 2002 a deficiency in petitioner’s
Federal income tax of $3,595. After a concession,1 the issue for
decision is whether petitioner engaged in her rental real estate
activity in 2002 with the objective of making a profit.
Background
The stipulation of facts and the exhibits received into
evidence are incorporated herein by reference. At the time the
petition in this case was filed, petitioner resided in New York,
New York.
During 2002, petitioner was employed as an assistant dean at
Columbia University Medical Center (CUMC). Petitioner, among
other things, organized fundraising events for CUMC and
maintained alumni and student relations. One of the locations at
which petitioner conducted her fundraising events was Lubec,
Maine.
History of the Cottages
In 1979, petitioner visited Lubec, a small town located in a
remote area of Maine near the Canadian border. Lubec has a
depressed economy because it does not have an industry. Lubec
also is not viable as a tourist attraction because it is located
far from major transportation and population centers.
Petitioner, nevertheless, saw potential in Lubec and conceived
1Petitioner concedes that she is required to include in her
income for 2002, an additional tax refund of $475 from New York
State.
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