John Boreta - Page 1

                                 T.C. Memo. 1997-561                                  

                               UNITED STATES TAX COURT                                

                             JOHN BORETA, Petitioner v.                               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 25943-93.          Filed December 23, 1997.                 

                    Held:  Petitioner did not adequately disclose on his              
               1988 Federal income tax return relevant facts regarding the            
               tax treatment of a claimed business interest expense                   
               deduction.  Petitioner is liable for an addition to tax                
               under sec. 6661, I.R.C.                                                

               Walter B. Thurmond and Charles B. Koerth, for petitioner.              
               Allan D. Hill, for respondent.                                         

                                 MEMORANDUM OPINION                                   

               SWIFT, Judge:  Respondent determined a deficiency of                   
          $174,822 in petitioner’s Federal income tax for 1988 and                    

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