interest due on $4,737, and under section 6659 in the amount of
$459.30, and for increased interest under section 6621(c).
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year at issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. The issues for decision for the taxable year 1984 are
as follows:
(1) Whether petitioner is entitled to claimed deductions
and a claimed investment tax credit in connection with a master
recording lease transaction. We hold that he is not.
(2) Whether petitioner is entitled to a claimed business
bad debt deduction in the amount of $76,056 in connection with
his investment in the Carter Co. We hold that he is not.
(3) Whether unemployment compensation petitioner received
in the amount of $5,312 is taxable as determined by respondent.
We hold that it is.
(4) Whether petitioner is subject to self-employment tax on
his self-employment income. We hold that he is.
(5) Whether petitioner is liable for an addition to tax for
negligence under section 6653(a)(1) as determined by respondent.
We hold that he is.
(6) Whether petitioner is liable for an addition to tax for
a valuation overstatement under section 6659 as determined by
respondent. We hold that he is.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011