OHANA v. COMMISSIONER OF INTERNAL REVENUE

Docket Nos. 16014-11, 25896-11.

T.C. Memo. 2014-83

ISSACHAR OHANA AND RACHEL OHANA, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed May 8, 2014.


Attorney(s) appearing for the Case

Martin Aaron Shainbaum and Bryant W.H. Smith , for petitioners.

Jon D. Feldhammer , Thomas R. Thomas , Patricia A. Donahue , and Trent D. Usitalo , for respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

HOLMES, Judge.

Issachar and Rachel Ohana moved from Israel to Northern California in 2003. Soon after, they bought two houses and from 2007 through 2009 poured money into them. They claim deductions for the cost of these improvements, and argue that they were in the trade or business of real-estate development, without ever having bought or sold any real estate during the years before us. They did own the two properties...

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