Gary Beecher Delores Beecher v. Commissioner of Internal Revenue

COVELLO, District Judge.

This is an appeal from a decision of the United States Tax Court upholding a tax deficiency determination of the Commissioner of Internal Revenue (“Commissioner”). 1 It is brought pursuant to Internal Revenue Code § 7482. 2 The appellants, Gary Beecher and Dolores Beecher (“Beechers”) challenge the tax court’s ruling that the Beechers cannot apply losses from their various rental properties to offset rental income derived from leases of office space in their home to lessee corporations which they happen to own.

The issues presented are: 1) whether Treasury Regulation §…