HOSKINS v. COMMISSIONER OF INTERNAL REVENUE
T.C. Memo. 2013-36
GARY L. HOSKINS AND CYNTHIA HOSKINS, Petitioners,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent.
Docket No. 3850-10.
United States Tax Court.
Filed February 4, 2013.
MEMORANDUM FINDINGS OF FACT AND OPINIONCOHEN, Judge.
Respondent determined deficiencies and penalties with respect to the joint income tax returns of petitioners as follows:
Penalty
Year Deficiency sec. 6662(a)
2006 $43,721 $8,744.20
2007 11,371 2,274.20
The issues for decision are (1) whether petitioners are entitled to deduct claimed rental real estate losses after section 469 passive loss limitations are considered; (2) whether petitioners are entitled to all claimed deductions for real property expenses; and (3) whether petitioners are liable for accuracy-related penalties under section 6662(a). Unless otherwise indicated all section references are to the Internal Revenue Code for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACTSome of the facts have been stipulated, and the stipulated facts are incorporated in our findings by this reference. At the time the petition was filed, and during the years in issue, petitioners resided in Florida. During the years in issue, Cynthia Hoskins worked part time as a reservationist for U.S. Airways.