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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.
Background
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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