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E against income from other sources in arriving at total income
for each such year.
Respondent issued to petitioner a notice of deficiency
(notice) with respect to his taxable years 1995 through 1999. In
that notice, respondent determined petitioner’s claimed Aldus
Green loss for each of those years to be a passive activity loss
under section 469, allowed each such loss to the extent of income
from passive activities for each such year, and disallowed the
following amount of petitioner’s claimed Aldus Green loss for
each such year:
Year Amount
1995 $44,108
1996 52,415
1997 44,495
1998 41,317
1999 48,773
OPINION
Petitioner concedes that petitioner’s claimed Aldus Green
loss for each of the years at issue is a passive activity loss as
defined in section 469(d)(1) and that section 469(a) disallows
each such loss.3 It is petitioner’s position, however, that the
application of section 469 to petitioner’s claimed Aldus Green
3Petitioner also concedes that he is liable for additions to
tax under sec. 6651(a)(1) for the taxable years 1996 and 1997 and
for accuracy-related penalties under sec. 6662(a) for all the
taxable years at issue.
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