Antonio B. Secapure - Page 1
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T.C. Memo. 2004-18
UNITED STATES TAX COURT
ANTONIO B. SECAPURE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5019-02. Filed January 28, 2004.
Charles E. Smith, Jr., for petitioner.
Daniel J. Parent, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: Respondent determined a deficiency in
petitioner’s 1995 Federal income tax of $37,344, and additions to
tax for 1995 for failure to (a) file a return and (b) pay
estimated tax. After concessions, the issues for decision are:
1. Whether petitioner’s basis in property related to a
Chevron gas station business that he sold in 1995 was zero, as
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