CUSICK v. COMMISSIONER

Docket No. 4186-96.

76 T.C.M. 241 (1998)

T.C. Memo. 1998-286

Tim H. Cusick v. Commissioner.

United States Tax Court.

Filed August 5, 1998.


Attorney(s) appearing for the Case

Marc K. Sellers, Portland, Ore., and Paul A. Stamnes, for the petitioner. Wesley F. McNamara, for the respondent.


MEMORANDUM OPINION

PARR, Judge:

Respondent determined a $156,139 deficiency in petitioner's 1992 Federal income tax and additions to tax under sections 6651(a)1 and 6654(a) in the amounts of $39,035 and $6,806, respectively.

After concessions, the issues for decision are: (1) Whether for 1992 petitioner is entitled to deduct 50 percent of the substantiated expenses incurred for certain rental real estate. This turns on...

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