- 2 - additions to tax under sections 6653(a)(1) and 6661 in the amounts of $8,741 and $43,706, respectively. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for 1988, and all Rule references are to the Tax Court Rules of Practice and Procedure. The only issue remaining for decision is whether petitioner adequately disclosed on his 1988 Federal income tax return relevant facts regarding the tax treatment of a claimed business interest expense deduction. Background This case has been submitted for decision fully stipulated pursuant to Rule 122. When the petition was filed, petitioner resided in Houston, Texas. On Schedule C (Profit or Loss from Business or Profession) of petitioner’s 1988 Federal income tax return, petitioner claimed a business interest expense deduction of $813,462, and petitioner described his business solely by reference to principal business code 5777, “Other real estate, insurance, and financial activities”. Other than listing the $813,462 amount on Schedule C, on his 1988 Federal income tax return, petitioner made no special disclosure with regard to the above claimed interest expense deduction.Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011