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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.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioners
Petitioners are married and lived in Bothell, Washington,
when they filed their petition. From August 1977 to August 1979,
petitioner was an Internal Revenue Service revenue agent. From
August 1979 to 1984, petitioner was comptroller for a company in
Seattle. From 1984 to 1986, petitioner earned about $65,000 per
year as a vice president of a real estate development company
that converted apartments to condominiums. Petitioner had
invested in real estate and had owned other businesses. He owned
an ice business and an accounting business in the 1970's. He and
his wife owned an ice cream and candy store in the 1980's.
During the 1970's and 1980's, petitioner bought several houses
and a condominium (most jointly with his brother) as rentals or
as investments, and bought a condominium to rent to his daughter
and son-in-law.
Petitioner was unemployed in the summer of 1986. He began
to look for work for which he could earn at least $70,000 per
year.
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