Bruce Selig and Elaine Selig - Page 2

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               Richard J. Sapinski and Robert J. Alter, for petitioners.              
               Robert A. Baxter, for respondent.                                      


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               HALPERN, Judge:  Respondent determined deficiencies in                 
          income tax and additions to tax as follows:                                 
                                   Additions to Tax and Penalties                     
                                        Sec.      Sec.      Sec.                      
               Year    Deficiency    6651(a)      6661    6662(a)                     
               1987     $88,837         ---      $39,264     ---                      
               1988      62,391         ---       13,020    ---                       
               1989      58,838       $22,260     ---  $11,768                        
               1990 51,762      ---         ---      10,352                           
          After concessions, the issues remaining for decision are                    
          (1) whether petitioners are allowed depreciation deductions with            
          regard to certain "exotic automobiles" owned and exhibited by               
          petitioner husband, (2) whether Exotic Bodies, Inc., an                     
          S corporation within the meaning of section 1361(a)(1), was                 
          engaged in a trade or business such that petitioners may claim              
          certain losses from that corporation, (3) the basis of certain              
          shares of stock in BSG Corp., and (4) petitioners' liability for            
          the additions to tax under section 6661 and penalties under                 
          section 6662(a) set forth above.                                            
               In their opening brief, petitioners proposed no findings of            
          fact or made any argument with regard to the basis of any shares            
          in BSG Corp.  In her opening brief, respondent argued that, since           




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