Paul M. and Wanda E. Harmon - Page 3
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other court, and this opinion shall not be treated as precedent
for any other case.
Petitioners claimed deductions for a rental real estate loss
of $68,796 for the taxable year 2001 that respondent denied,
resulting in a deficiency in petitioners’ income tax for the year
of $18,937. The sole issue for decision is whether petitioner-
wife was a real estate professional and thus not subject to the
passive activity loss rule of section 469(c)(2) and (4).2
Some of the facts have been stipulated, and they are so
found. We incorporate by reference the parties’ stipulation of
facts and accompanying exhibits.
At the time the petition was filed, Paul M. Harmon (Mr.
Harmon) and Wanda E. Harmon (petitioner or Mrs. Harmon) resided
in Oakland, California.3
With a background in English and a master’s degree in
counseling, petitioner was employed by both Golden Gate
2 The two other adjustments contained in the notice of
deficiency are mechanical in nature and are dependent on the
final calculation of petitioners’ adjusted gross income.
3 Although Mr. and Mrs. Harmon both signed the petition, as
only Mrs. Harmon appeared in person at trial and as this case
solely concerns Mrs. Harmon’s status as a real estate
professional, we refer to Mrs. Harmon alone as petitioner. We
refer to Mr. and Mrs. Harmon jointly as petitioners.
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Last modified: November 10, 2007