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