Carolyn D. Fenderson - Page 3

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               Respondent determined a $22,584 deficiency in petitioner’s             
          2002 Federal income tax.  The issue for decision is whether                 
          petitioner is entitled to a deduction for a loss from her real              
          estate activities.  The resolution of the issue depends, in part,           
          upon whether section 469(c)(7) applies to petitioner for the year           
          in issue.                                                                   
               Some of the facts have been stipulated and are so found.  At           
          the time the petition was filed in this case, petitioner resided            
          in Ohio.                                                                    
               In January 2000, petitioner started employment as an account           
          manager for Symantec Corporation, a company that markets a                  
          popular computer security software program (Symantec).  She was             
          so employed during 2002, and although expected to develop new               
          business, she was primarily responsible for servicing eight                 
          existing customers.  To that end, she regularly kept in contact             
          with those customers and was always available to them in order to           
          ensure that any problems or concerns any might have would be                
          properly and promptly resolved.  If the customer’s problem were             
          of a technical nature, petitioner would arrange for one or more             
          Symantec software engineers to get involved.                                
               During the first year of her employment with Symantec,                 
          petitioner frequently traveled to customers and potential                   

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