Leonard L. Leighton and Joyce S. Leighton - Page 2

                                          2                                           
               Petitioners Leonard L. and Joyce S. Leighton were residents            
          of San Antonio, Texas, in the years 1987 and 1988, and at the               
          time the petition was filed in this case.  For those years, they            
          filed joint income tax returns on the cash basis.  Hereinafter,             
          references to petitioner are to Leonard L. Leighton.                        
               The issues we must decide in this case are:  (1) Whether               
          respondent erred in determining that petitioners had unreported             
          ordinary income in 1987 of $762,685; (2) whether respondent erred           
          for 1987 in determining that petitioners had unreported net                 
          capital gains of $653,787; and (3) whether petitioners had net              
          capital losses in excess of any reportable capital gains for                
          1987.  Minor additional adjustments to income, as well as                   
          additions to tax for each year for negligence and for substantial           
          understatement of tax under sections 6653 and 6661, were raised             
          as issues in the petition herein, but were never mentioned by               
          petitioners thereafter, either at trial or on brief, and are                
          deemed to be conceded.  See Rule 151.                                       
               Petitioner is a practicing attorney at law in San Antonio,             
          Texas, having received his license to practice in 1961, and he              
          also holds a masters in taxation degree from New York University.           
          He has taught law at the law school at St. Mary's University.  At           
          least since 1981, petitioner has been a partner in a law firm in            
          San Antonio, Texas, and Mrs. Leighton has worked for such firm as           
          a secretary.  Petitioner was principal partner of and held a                
          controlling interest in said law firm from 1981 through 1988, and           




Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011