Timothy Demitri Brown - Page 2

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               After concessions, the issues for decision are:  (1) Whether           
          Mr. Brown is entitled to a loss deduction in the amount of                  
          $30,900 for currency that was seized by Louisiana law enforcement           
          officials pursuant to a civil forfeiture statute; (2) whether Mr.           
          Brown is entitled to a Schedule E loss deduction in the amount of           
          $5,000 for a deposit he made on a townhouse; (3) whether Mr.                
          Brown is entitled to claim a deduction for a theft loss in the              
          amount of $22,300; and (4) whether Mr. Brown is liable for self-            
          employment taxes under the provisions of section 1401.                      

                                  FINDINGS OF FACT                                    

               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  Mr. Brown resided in                
          Alexandria, Louisiana, at the time the petition was filed.                  
               On September 28, 1993, Mr. Brown was arrested along with two           
          other individuals in Lake Charles, Louisiana.  At the time of his           
          arrest, Mr. Brown was carrying $30,900 in currency.  Law                    
          enforcement officials confiscated the currency as suspected drug            
          money.  On November 2, 1993, before the State of Louisiana had              
          instituted formal judicial forfeiture proceedings, Mr. Brown                

          1(...continued)                                                             
          Practice and Procedure.                                                     
          2On Mar. 18, 1996, respondent filed a report to the Court                   
          conceding that Mr. Brown was not liable for the accuracy-related            
          penalty under sec. 6662(a).                                                 




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