Eric L. and Kay K. Jones - Page 2

                                                - 2 -                                                 
            all Rule references are to the Tax Court Rules of Practice and                            
            Procedure.                                                                                
                  After a concession,1 the issues to be decided involve                               
            petitioners' entitlement to business bad debt deductions claimed                          
            by them for certain payments made by petitioner Eric L. Jones                             
            (petitioner) during the year in issue.                                                    
                                        FINDINGS OF FACT                                              
                  Some of the facts have been stipulated for trial pursuant to                        
            Rule 91.  The parties' stipulations of fact are incorporated                              
            herein by reference and are found as facts in the instant case.                           
                  At the time they filed their petition in the instant case,                          
            petitioners resided in Dublin, Georgia.  During the taxable year                          
            in issue, petitioner was an attorney licensed to practice law in                          
            the State of Georgia.                                                                     
                  Petitioner invested in real estate in order to create the                           
            opportunity for his law firm to earn income by performing real                            
            estate syndications, title searches, and loan closings.  During                           
            the taxable year in issue, however, petitioner was not involved                           
            in the business of lending money or in the business of selling                            
            corporations that he had created, funded, or promoted.                                    



            1     In the opening brief, respondent conceded that "there are no                        
            additions to the tax applicable in this case" and made no                                 
            argument as to the accuracy-related penalty pursuant to sec.                              
            6662.  Accordingly, we consider the penalty to have been                                  
            conceded.                                                                                 




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Last modified: May 25, 2011