Henry Allen Waters - Page 2

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          section 1034(a);1 (2) whether petitioner is entitled to an                  
          interest deduction in excess of that allowed by respondent; and             
          (3) whether petitioner is liable for the accuracy-related penalty           
          under section 6662(a) for a substantial understatement of his tax           
          liability.                                                                  
                                  FINDINGS OF FACT2                                   
               Petitioner resided in Fairfield, California, at the time his           
          petition was filed.                                                         
               During 1989, petitioner decided to sell his principal                  
          residence in Richmond, California, with the intention of                    
          purchasing a new home in the area.  In April 1989, prior to                 
          selling his Richmond home, petitioner engaged the services of a             
          real estate agent to assist him in finding and purchasing a new             
          home.  Shortly thereafter, petitioner located a home he wanted to           
          purchase and applied to a mortgage financing company for a loan.            
          Petitioner's loan application was denied, however, because he had           
          filed for bankruptcy in 1988 and his obligations in that regard             
          had not yet been resolved.  At the time petitioner applied for              
          the loan, he was making payments of approximately $580 per month            
          pursuant to a debt repayment plan established in accordance with            
          his bankruptcy case.                                                        


               1 Unless otherwise indicated, all section references are to            
          the Internal Revenue Code in effect for the year in issue, and              
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
               2 The parties have stipulated facts and exhibits which are             
          incorporated by this reference.                                             


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