J.J. Zand - Page 68

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               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.  On             





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