Clifford E. Barbour, Jr. and Dorothy D. Barbour - Page 3




                                        - 3 -                                          
          proper disposition of petitioner’s motion.  See Rule 232(a)(2).              
          We therefore decide the matter before us based on the record that            
          has been developed to date.                                                  
          Background                                                                   
               Petitioner resided in Knoxville, Tennessee, at the time that            
          the petition was filed with the Court.                                       
               For the relevant periods involved herein petitioner owned               
          stock in several businesses, including White Pine Truck & Trailer            
          (White Pine), Tamperproof Identification Company, Inc.                       
          (Tamperproof), Identrol Corporation (Identrol), and Barbour Hill             
          Bakery (Barbour Hill).                                                       
               By notice dated December 12, 1996, respondent determined a              
          deficiency in petitioner’s income tax in the amount of $47,9464              
          for the taxable year 1992 based on the following adjustments:                
               First, respondent determined that petitioner was not                    
          entitled to claim a loss in the amount of $162,033 in connection             
          with White Pine based on the determination that White Pine was a             
          passive activity and that the passive activity loss from such                
          activity would be limited to passive income.  In the alternative,            
          respondent determined that petitioner would not be entitled to               
          claim the $162,033 loss because petitioner had not established               
          any basis in his White Pine stock.                                           




               4  All monetary amounts are rounded to the nearest dollar.              




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  Next

Last modified: May 25, 2011