- 2 - Federal income tax in the amount of $6,287. After petitioner's concessions2, the sole issue for decision is whether petitioner is entitled to deduct an ordinary loss in the amount of $18,750 as a result of his investment in Geotech Energy Corporation. Some of the facts have been stipulated and are so found. The stipulations of fact and attached exhibits are incorporated herein by this reference. Petitioner resided in Spokane, Washington, on the date the petition was filed in this case. Petitioner was married during the year in issue and filed a 1991 joint Federal income tax return with his wife. A statutory notice of deficiency was mailed to petitioner and his wife. However, only petitioner Alfred C. Heston has filed a petition with this Court. According to his testimony in November 1987, petitioner invested $18,750 in Geotech Energy Corporation (hereinafter Geotech) to purchase a 1/4 percent overriding royalty interest in the Rio Blanco County, Colorado oil, gas, and other mineral lease that had been procured by Geotech (hereinafter Rio Blanco lease). Petitioner testified that Geotech obtained oil leases and sold overriding royalty interests in those oil leases to individual 2 In her notice of deficiency, respondent determined that petitioner's employee business expenses should be disallowed to the extent of $1,775 and a $10,000 long-term capital loss should be recharacterized as a nonbusiness bad debt, and therefore deducted as a short-term capital loss. Petitioner concedes these issues.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011