- 3 - (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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011