Harry D. Bledsoe and Annie L. Bledsoe - Page 2

                                                - 2 -                                                   

            Year   Deficiency           Additions to Tax             Penalty                            
            Sec.           Sec.       Sec.                                                              
            6653(a)(1)(A)  6653(a)(1)(B)   6661                                                         
            1987    $91,789        $4,589          1         $22,947                                    
                                                                                                       
            Sec.            Sec.      Sec.                                                              
            6651(a)(1)      6653(a)(1)   6661                                                           
            1988     40,848             8        $2,050      10,212                                     
                                                                              Sec.                     
            6662                                                                                        
            1989          9                                                    $2                       
                  1 50 percent of the interest due on $91,789.                                          
                  All section references are to the Internal Revenue Code in                            
            effect for the years in issue, and all Rule references are to the                           
            Tax Court Rules of Practice and Procedure, unless otherwise                                 
            indicated.                                                                                  
                  After concessions, the issues remaining for our                                       
            consideration are:  (1) Whether petitioners are entitled to a bad                           
            debt deduction in the amount of $55,000; (2) whether petitioners                            
            are entitled to Schedule E deductions for legal fees for 1987 and                           
            1988 in the amounts of $88,199 and $37,419, respectively; (3)                               
            whether petitioners are entitled to section 1244 stock loss                                 
            deductions for 1988 and 1989 in the amounts of $92,500 and                                  
            $96,503, respectively; (4) whether petitioners received dividend                            
            distributions from their S corporation in 1987, 1988, and 1989 in                           
            the amounts of $106,212, $66,423, and $48,632, respectively; (5)                            
            whether petitioners are liable for additions to tax for 1987 and                            








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