MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge: Respondent determined that the following
deficiencies are due from petitioners:
Additions to Tax
Year Income Tax Sec. 6662(a)*
1989 $10,242 $2,048
1990 1,639 -0-
1991 2,972 594
*We note that in 1989, Pub. L. 101-239, sec. 7721(a), 103
Stat. 2395, 2400, as part of the amendments to subchapter A of
chapter 68, repealed previous section 6662(a), which had provided
for certain additions to tax. The repeal was effective for
returns the due date for which (determined without regard to
extensions) was after December 31, 1989. Thus, respondent's
determination as to additions to tax under former sec. 6662(a) is
improper.
Unless otherwise indicated, all section references are to
sections of the Internal Revenue Code in effect for the years at
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
Respondent has made a number of concessions, including the
concession that there are no additions to tax. The only issue
remaining for decision is whether petitioners are entitled to a
casualty loss deduction for 1990.
FINDINGS OF FACT
Some of the facts have been stipulated and are incorporated
herein by this reference.
Petitioners resided in Durham, New Hampshire, when they
filed their petition.
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