- 2 - Following concessions, we must decide: 1. Whether petitioner may deduct certain payments that he made to the Hollywood, Florida, police department as a charitable contribution. We hold he may not. 2. Whether petitioner may deduct those payments as an expense under section 212 or a portion of these payments as a casualty loss under section 165. We hold he may not. 3. Whether petitioner is entitled to a bad debt deduction with respect to two "loans". We hold he is not. 4. Whether petitioner is liable for an addition to his 1987 tax under section 6651(a)(1). We hold he is. Unless otherwise stated, section references are to the Internal Revenue Code in effect for the year in issue. Rule references are to the Tax Court Rules of Practice and Procedure. Dollar amounts are rounded to the nearest dollar. FINDINGS OF FACT Some facts have been stipulated and are found accordingly. The stipulated facts and exhibits are incorporated herein by this reference. Petitioner resided in Hollywood, Florida, when he filed his petition. On August 28, 1986, the Hollywood, Florida, police department (Police Department), with the assistance of the United States Marshals (collectively referred to as Officers), searched petitioner's home pursuant to a valid search warrant. The Officers found 334 grams of cocaine, $7,362 in United StatesPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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