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JORMAN v. COMMISSIONER

Docket No. 11288-93.

68 T.C.M. 1435 (1994)

T.C. Memo. 1994-613

John K. Jorman, Jr. and Audrey Jorman v. Commissioner.

United States Tax Court.

Filed December 14, 1994.

Attorney(s) appearing for the Case

John K. Jorman, Jr. and Audrey Jorman, pro sese. Brian M. Harrington, for the respondent.

Memorandum Opinion

GOLDBERG, Special Trial Judge:

This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181 and 182.1 Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1990 in the amount of $3,594.

The issue for decision is whether petitioners' real estate activity was engaged in for profit in accordance with section 183, thereby allowing petitioners to deduct expenses...

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