Robert W. and Jennifer J. Fritz - Page 4

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          which the IRS accepted the Form 706 and the valuation of the La-            
          Z-Boy stock contained therein.                                              
               Under the terms of Selma Fritz' will, she bequeathed to Mr.            
          Fritz 75 percent of the rest, residue, and remainder of her                 
          estate.  The remaining 25 percent was bequeathed to petitioners'            
          son, Timothy R. Fritz.  Included within the residue of Selma                
          Fritz' estate were her shares of La-Z-Boy stock.  Upon receipt of           
          this stock, Mr. Fritz and Timothy Fritz placed the shares in a              
          stock account at the investment firm of A.G. Edwards & Sons, Inc.           
          (A.G. Edwards), in the names of Robert W. Fritz, Jennifer Joan              
          Fritz, and Timothy R. Fritz.  In 1985, petitioners and Timothy              
          Fritz sold 5,406 shares of La-Z-Boy stock for $225,373.                     


          Car and Truck Expenses                                                      

               On Schedule C of their 1987 Federal income tax return,                 
          petitioners claimed a deduction in the amount of $21,364 for car            
          and truck expenses, which they argue represent expenses incurred            
          by Mr. Fritz in carrying on his tree trimming business.  In the             
          notice of deficiency, respondent allowed only $11,721 of the                
          deduction, because petitioners failed to establish that all the             
          expenses claimed were paid and that they constituted ordinary and           
          necessary business expenses.  Respondent's determination is                 
          presumed correct, and petitioners bear the burden of proving                

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