- 2 - made by petitioner to Color Trick, Inc. (Color Trick); and (2) whether petitioner may claim an ordinary loss pursuant to section 1244 attributable to the worthlessness of his stock in Color Trick. Unless otherwise noted, all section references are to the Internal Revenue Code as in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT Some of the facts and certain exhibits have been stipulated for trial pursuant to Rule 91. The stipulated facts are incorporated herein by reference and are found accordingly. At the time he filed the petition in the instant case, petitioner resided in Dunedin, Florida. Beginning in 1978 and during the times relevant to the instant case, petitioner was an anesthesiologist. During 1980, petitioner and certain other anesthesiologists formed a partnership known as Anesthesia Associates of Dunedin (medical group) that provided services at a local hospital. Petitioner handled operation of the medical group. Petitioner worked between 40 and 50 hours per week as an anesthesiologist and took 18 weeks of vacation per year. From 1980 until 1984 or 1985, petitioner invested with a builder in the construction and sale of homes on speculation. Additionally, petitioner and another physician in the medical group owned an apartment building. Petitioner maintained thePage: 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