Tax Court Sustains IRS’s Disallowance of Couple’s Deductions

Tax Court Sustains IRS’s Disallowance of Couple’s Deductions

U.S. Tax Court

The Tax Court, sustaining penalties, held that a couple of nonresident U.S. citizens wasn’t entitled to additional itemized deductions, their rental loss deductions are limited under <a href="/research/federal/usc26/469" resolve="/lr/resolve//cq8z">section 469</a> because the wife wasn’t a real estate professional, and they weren’t entitled to additional self-employed health insurance deductions or a foreign tax credit carryover.

Related to <a data-mce-href="2cg0v" href="/lr/resolve//2cg0v" target="_blank">Larkin v. Commissioner</a>, No. 17-1252 (D.C. Cir. 2020).

The Tax Court, sustaining penalties, held that married nonresident U.S. citizens aren’t entitled to additional itemized deductions, their rental loss deductions are limited under section 469 because the wife wasn’t a real estate professional, and they aren’t entitled to additional self-employed health insurance deductions or a foreign tax credit carryover.

The Tax Court, sustaining penalties, held that a couple of nonresident U.S. citizens wasn’t entitled to additional itemized deductions, their rental loss deductions are limited under section 469 because the wife wasn’t a real estate professional, and they weren’t entitled to additional self-employed health insurance deductions or a foreign tax credit carryover.

Sec. 162 Trade or business expenses

Sec. 163 Interest

Sec. 469 Passive activity losses and credits limited

Sec. 901 Taxes of foreign countries and of possessions of United States

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Tax Court Sustains IRS’s Disallowance of Couple’s Deductions