- 3 - determine that it is not deductible as a business bad debt, then petitioner is entitled to claim the $400,000 as a short-term capital loss; i.e., a nonbusiness bad debt. Sec. 166(d)(1) and (2). We also consider whether petitioner is liable for an accuracy-related negligence penalty pursuant to section 6662(a) for the taxable year 1990.2 FINDINGS OF FACT3 Lee D. Froehlich (petitioner), at the time of the petition in this case, resided in Simi Valley, California. Petitioner, at various times, has been engaged in the field of selling new and used automobiles. Petitioner's professional career has been in the retail automobile business, including positions such as salesperson, sales manager, general manager, and, ultimately, owner of a dealership. For the relevant years, petitioner was president and owner of FRO Enterprises, Inc., an Acura automobile dealership (the auto dealership). In 1967, petitioner was inducted into the U.S. Army, thus interrupting his college education at the University of Nebraska. In 1969, petitioner began developing skills and expertise selling automobiles in Kansas City, Kansas. Petitioner also received management training during this particular interval. From 1972 2 Respondent has conceded that petitioner is not liable for the sec. 6661 addition to tax for the taxable year 1987. 3 The parties' stipulations of facts and exhibits are incorporated by this reference.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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