Derwyn J. Booker - Page 2

          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.                                            







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