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tax under section 6651(a)(1) in the amount of $302. The issues
for decision are: (1) Whether petitioner is entitled to a
deduction for a nonbusiness bad debt under section 166; and (2)
whether petitioner is liable for the addition to tax under
section 6651(a)(1) for failure to timely file his income tax
return.
At the time of the filing of this petition, petitioner
resided in Simi Valley, California. The stipulation of facts and
attached documents are incorporated herein by this reference.
In 1988, petitioner was a car salesman and lived in Garden
Grove, California. Prior to and during 1988, petitioner and Roy
Maxted (Maxted) were good friends. Petitioner and Maxted are
originally from Montana. Petitioner was involved in a previous
business venture with Maxted and socialized with Maxted when he
visited Montana. Petitioner kept in touch with Maxted through
periodic telephone calls and occasional visits.
At the beginning of 1988, Maxted lived in Helena, Montana,
and made car shades.2 The car shades were made of an aluminum-
like material which was only produced on the east coast three to
four times per year. The car shades also had suction cups so
that they could be fastened to the windshield. Sometime in 1988,
Maxted relocated to Phoenix, Arizona, to continue his car shade
2 Car shades are placed inside a car to block sunlight
from coming through the windshield and heating the interior of
the car.
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