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Pursuant to respondent's motion, these cases have been
consolidated for trial, briefing, and opinion. All section
references are to the Internal Revenue Code in effect for the
years in issue. All Rule references are to the Tax Court Rules
of Practice and Procedure.
After concessions,2 the issues for decision are:
Issues With Respect to the Dickersons
1. Whether the Dickersons incurred taxable gain in the
amount of $57,855 in the 1990 tax year from the sale of two lots
of real property;
2. whether the Dickersons received rental income in the
amount of $3,550 in the 1990 tax year from the rental of real
property;
3. whether the Dickersons received unreported taxable
income in the 1989 and 1990 tax years in the amounts of $55,097
and $2,800, respectively;
2 The following issues have been conceded:
The Michoff, Srs., claimed exemptions to which they were not
entitled for their sons, Michael Michoff, Jr., and Steven
Michoff, in the 1986 tax year.
The Michoff, Srs., claimed exemptions to which they were not
entitled for Steven Michoff in the 1987 and 1989 tax years.
The Michoff, Srs., received unreported interest income in
the 1989 and 1990 tax years in the amounts of $54 and $62,
respectively.
The Michoff, Srs., failed to report taxable State income tax
refunds on their 1989 and 1990 income tax returns in the amounts
of $39 and $159, respectively.
Michael Michoff, Jr., received unreported interest income in
the 1986 and 1987 tax years in the amounts of $2,089 and $854,
respectively.
Respondent concedes the deficiency against Kimberly Michoff
for the 1986 tax year.
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