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(comps) that he received from Trump Plaza Associates, t/a Trump
Plaza Hotel and Casino (Trump). We hold he can.2 Section
references are to the Internal Revenue Code in effect for the
years in issue. Rule references are to the Tax Court Rules of
Practice and Procedure. Dollar amounts are rounded to the
nearest dollar.
Background3
Petitioner resided in Secaucus, New Jersey, when he
petitioned the Court. He filed 1987 and 1988 Federal income tax
returns on November 20, 1989.4 He filed a 1989 Federal income
tax return shortly after April 15, 1990, and he did so without
receiving an extension of time under section 6081(a). All of
petitioner's returns were prepared by a certified public
accountant, and petitioner filed them using the status of
"Married filing separate return". On each return, petitioner
reported profits from his horse brokerage business called Buck
Chance Stables (the Stables), which was conducted as a sole
proprietorship. Petitioner reported that the Stables' profits
were $3,169,881 in 1987, $785,900 in 1988, and $796,031 in 1989.
2 Accordingly, we also hold that petitioner is not liable
for the additions to tax or penalty for substantial
understatements.
3 The stipulated facts and the exhibits submitted therewith
are incorporated herein by this reference.
4 He also filed an amended 1987 tax return on or about the
same day.
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