- 2 - 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 potentialPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008