- 3 -
which we so find. The stipulations of fact filed by the parties
and attached exhibits are incorporated herein by this reference.
Although the issues remaining for decision are principally
factual, we need find few facts in addition to those stipulated
by the parties. Accordingly, we have not divided our report into
two sections, one comprising our findings of fact and the other
setting forth our opinion. The additional findings we must make
are contained in the discussion that follows. After setting
forth certain background information, we shall address (1) the
adjustments made by respondent that remain in dispute and (2) the
additions to tax that remain in dispute. Petitioner bears the
burden of proof on all questions of fact. Rule 142(a).
I. Background
Petitioner resided in Huntington, New York, at the time the
petition in this case was filed.
During 1986, petitioner was employed as an automobile
salesman by two different automobile dealerships, Sports Imports
Inc. (Sports Imports) and Rallye Motors, Inc. (Rallye Motors).
Petitioner was unemployed from approximately April 1986, when his
employment by Sports Imports ended, until December 1986, when his
employment by Rallye Motors began. During 1987 and 1988,
petitioner was employed as an automobile salesman by Rallye
Motors. During 1987 and 1988, petitioner owned a horse racing
and breeding business. Petitioner is a frequent gambler.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011