Jack R. and Patricia J. Finnegan - Page 2

                                        - 2 -                                         

          incurred in connection with their construction and attempted sale           
          of a house under section 162.1                                              
                                  FINDINGS OF FACT                                    
               Oral stipulations were made at trial.  The oral stipulation            
          of facts and the referenced exhibits are incorporated herein by             
          this reference.  Petitioners, husband and wife, resided in Santa            
          Ana, California, at the time they filed their petition.                     
               During 1991, petitioner Jack R. Finnegan (Mr. Finnegan) was            
          a construction consultant.  Mr. Finnegan ran his construction               
          consulting business out of his home in Santa Ana.  As a                     
          construction consultant, Mr. Finnegan was hired by third parties:           
          (1) To construct and estimate the cost of projects such as                  
          houses, banks, restaurants, schools, and hospitals; (2) to help             
          put bids together; and (3) to act as an arbitrator, architect,              
          quantity surveyor, developer, project manager, or general                   
          contractor.  As a construction consultant, Mr. Finnegan was paid            
          a fixed amount for each project.  He was compensated regardless             
          of whether the project was sold.                                            
               During 1991, in addition to his job as a construction                  
          consultant, Mr. Finnegan constructed a house located at 871                 
          Avenida Acapulco in San Clemente, California (the Acapulco                  



               1  All section references are to the Internal Revenue Code             
          in effect for the year in issue, and all Rule references are to             
          the Tax Court Rules of Practice and Procedure.                              




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  Next

Last modified: May 25, 2011