- 7 - improvements. Petitioner resided in the Solomons house from 1986 until February 1989 and paid no rent. From time to time, Solomons business was conducted in the Solomons house. Solomons owned the house and pledged it, along with the other partnership property, as collateral for loans obtained by the partnership. From 1986 to 1988, Solomons purchased additional adjacent property. The total acreage acquired by Solomons was 18.9339 acres. In February 1989, Solomons sold the 18.9339 acres of land, including the house that was occupied by petitioner, for $5,315,000. The Solomons house was destroyed by fire in February 1989. On February 24, 1989, petitioner and another person purchased a new home in St. Mary's County, Maryland, for $158,000. Other Background Petitioner prepared Allied's 1988 and 1989 Federal income tax returns. Petitioner prepared his own 1988 Federal income tax return. Petitioner's 1989 Federal income tax return was prepared by Clarkson Richard Sherwood (Sherwood), an accountant. OPINION Allied's Gross Income and Deductions Allied contends that respondent's determination of Allied's gross income should be reduced by $2,850 and $14,175 in 1988 and 1989, respectively.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011