Allied Marine Systems, Inc. - Page 7

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          improvements.  Petitioner resided in the Solomons house from 1986           
          until February 1989 and paid no rent.  From time to time,                   
          Solomons business was conducted in the Solomons house.  Solomons            
          owned the house and pledged it, along with the other partnership            
          property, as collateral for loans obtained by the partnership.              
          From 1986 to 1988, Solomons purchased additional adjacent                   
          property.  The total acreage acquired by Solomons was 18.9339               
          acres.                                                                      
               In February 1989, Solomons sold the 18.9339 acres of land,             
          including the house that was occupied by petitioner, for                    
          $5,315,000.  The Solomons house was destroyed by fire in February           
          1989.                                                                       
               On February 24, 1989, petitioner and another person                    
          purchased a new home in St. Mary's County, Maryland, for                    
          $158,000.                                                                   
          Other Background                                                            
               Petitioner prepared Allied's 1988 and 1989 Federal income              
          tax returns.  Petitioner prepared his own 1988 Federal income tax           
          return.  Petitioner's 1989 Federal income tax return was prepared           
          by Clarkson Richard Sherwood (Sherwood), an accountant.                     
                                       OPINION                                        
          Allied's Gross Income and Deductions                                        
               Allied contends that respondent's determination of Allied's            
          gross income should be reduced by $2,850 and $14,175 in 1988 and            
          1989, respectively.                                                         




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