In Simonelli v. Commissioner, T.C. Memo 2017-188, the Tax Court resolved the following issues in the favor of the IRS:
(1) whether petitioners are entitled to deduct expenses on Schedules C, Profit or Loss From Business, attributable to a law practice that petitioner Patrick Simonelli allegedly conducted with his son Antonio;
(2) whether petitioners are entitled to deduct rental real estate losses in excess of those respondent allowed, which depends on whether petitioner Jacqueline Simonelli qualified as a “real estate professional” during 2011 and 2012; and (3) are liable for accuracy related penalties. We resolve all issues in respondent’s favor.
Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.