- 2 - petitioners in a bench opinion dated January 11, 2005. We incorporate herein the facts set forth in that opinion. Background In 1996, Soraya Malowney decided to start a business involving the rehabilitation and sale of real estate. Mrs. Malowney had previous experience in the design and refurbishing of several homes, some of which were her former personal residences. After researching and evaluating several properties, she purchased, for $110,000, property located at 215 Northwest 74th Street in Lawton, Oklahoma. After purchasing the property, she discovered that it required an extensive amount of work. In October 1996, she began the renovation process and substantially completed the project by June 1997. In 1997, petitioners hired a real estate agent and listed the property for $214,000. In 1999, after hiring another agent and reducing the sales price, petitioners sold the property for $162,667. On Schedule C, Profit or Loss From Business, of their 1999 Federal income tax return, petitioners claimed a $52,046 business loss (i.e., sales proceeds of $162,500 less purchase price of $110,000, improvements of $95,736, commissions of $7,625, and other expenses of $1,185). On August 28, 2003, respondent issued petitioners a notice of deficiency relating to 1999 and determined that petitioners were not in a trade or business. On November 12, 2003, petitioners, while residing in Abilene, Texas, filed theirPage: Previous 1 2 3 4 5 Next
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