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1990 28,316.93 $7,293.98 5,663.39
After concessions,1 the issues for decision are: (1) Whether
petitioners can defer recognition of gain realized on receipt of
condemnation proceeds in taxable year 1989 under authority of
section 1033.2 We hold they may not. (2) Whether petitioners had
unreported interest income for taxable year 1989. We hold they
did. (3) Whether petitioners are entitled to the capital loss
claimed in taxable year 1989. We hold they are to the extent
provided below. (4) Whether petitioners had unreported dividend
income in taxable year 1989. We hold they did. (5) Whether
petitioners are liable for the section 6651 addition to tax
because they failed to timely file their 1990 income tax return.
We hold they are. (6) Whether petitioners are liable for
negligence under section 6662 for the years in issue. We hold
they are.
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulated
facts and the accompanying exhibits are incorporated into our
findings by this reference. Petitioners, Robert J. and Anne L.
Wilson, resided in Gaithersburg, Maryland, on the dates the
1 Pursuant to a stipulation of settled issues, the parties
resolved a number of issues raised by the pleadings. We leave it
to the parties to include these adjustments in their Rule 155
computations.
2 All section references are to the Internal Revenue Code in
effect for the taxable years in issue, and all Rule references
are to the Tax Court Rules of Practice and Procedure, unless
otherwise indicated.
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