John Boreta - Page 2

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          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.                                                                  







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