Faramarz and Mitra Elghanian - Page 2

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                                 Faramarz Elghanian                                   
                                   Addition to Tax and Penalty                        
               Year     Deficiency  Sec. 6661, I.R.C.  Sec. 6662(a), I.R.C.           
               1987      $1,867                                                       
               1988      186,159        $46,540                                       
               1989      219,622                            $43,924                   
                            Faramarz and Mitra Elghanian                              
                                Year   Deficiency                                     
                                   1990      3,949                                    
                                   1991      3,949                                    
               The issues for decision are:                                           
               1.   Whether petitioner’s2 loss on the expropriation of his            
          family’s Iranian property occurred in 1979, as respondent                   
          contends, or in 1986, as petitioners contend.  We hold that it              
          occurred in 1979.                                                           
               2.   Whether petitioner was a resident of the United States            
          in 1979.  We hold that he was not.                                          
               3.   Whether petitioner is entitled to a settlement of his             
          claimed deduction for expropriation losses on the same terms as             
          respondent’s settlement with petitioner’s father and brother.  We           
          hold that he is not.                                                        
               4.   Whether petitioner is liable for the addition to tax              
          under section 6661(a)3 for 1988 and the accuracy-related penalty            




               2  References to petitioner are to Faramarz Elghanian.                 
               3  Section references are to the Internal Revenue Code as              
          amended and in effect in the years in issue.  Rule references are           
          to the Tax Court Rules of Practice and Procedure.                           




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