- 152 - Likewise, no primary records of Southern Florida Real Estate Sales Corporation, such as invoices and canceled checks, are in evidence for the 1979 activity of Southern Florida Real Estate Sales Corporation or for the loss petitioner claimed from that entity. Therefore, petitioner is not entitled to a $3,228 loss from Southern Florida Real Estate Sales in computing 1979 taxable income. The only evidence of record for the claimed 1979 Admiralty Point Trust loss of $2,933 is a $3,000 check payable to Oscar Yanson with the notation "Admiralty Point venture". There is no evidence of when any loss was incurred on this real estate venture. Therefore, petitioner failed to establish that he incurred a loss of $2,933 from the Admiralty Point Trust in computing 1979 taxable income. On the 1979 tax return petitioner claimed a section 1244 loss of $20,895 from Danny's Hideaway. Respondent agrees that the evidence shows that petitioner incurred a loss when he sold his stock in Danny's Hideaway during 1979, but there is no evidence that the ordinary loss provisions of section 1244 are applicable. There is no evidence that petitioner incurred a claimed loss from Danny's Hideaway in the year 1980 in the amount of $5,771. Therefore, that claimed loss is disallowed. On the 1979 tax return petitioner claimed a farm loss of $128,458 attributable to a farm called Madison County Farm. OnPage: Previous 142 143 144 145 146 147 148 149 150 151 152 153 154 155 156 157 158 159 160 161 Next
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