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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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