Laurence L. Grabowski - Page 3




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          whether petitioner is entitled to certain deductions and is                 
          liable for the section 6662(a) accuracy-related penalty relating            
          to 1998.                                                                    
                                     Background                                       
               During 1998, petitioner and his brother, Patrick Grabowski,            
          operated several businesses including a property management                 
          company, a trailer park, and two motels (collectively, the                  
          businesses).  Petitioner was responsible for the onsite                     
          management of the businesses while Patrick paid the expenses and            
          maintained the books and records.                                           
               Petitioner, on his 1998 Federal income tax return, reported            
          losses relating to the businesses.  On April 25, 2005, respondent           
          issued petitioner a notice of deficiency relating to 1998.                  
          Respondent determined that petitioner did not substantiate the              
          losses relating to the businesses and was liable for the section            
          6662(a) accuracy-related penalty.                                           
               On July 25, 2005, petitioner, while residing in Lake Ozark,            
          Missouri, filed his petition with the Court.                                
                                     Discussion                                       
               Petitioner contends that the losses relating to the motels             
          and trailer park are deductible pursuant to section 162.  Section           
          162(a) allows as a deduction all the ordinary and necessary                 
          expenses paid or incurred during the taxable year in carrying on            
          a trade or business.  Petitioner must maintain sufficient records           







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