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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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Last modified: May 25, 2011