- 2 - decision is whether respondent may adjust petitioner's 1987 income under the mitigation provisions found in sections 1311 to 1315. Background This case was submitted fully stipulated under Rule 122. The stipulation of facts and exhibits are incorporated herein by this reference and found accordingly. At the time the petition was filed in this case, petitioner resided in Carson City, Nevada. Petitioner timely filed a Federal income tax return for 1987, subsequent to a valid extension, on July 18, 1988. Respondent mailed a statutory notice of deficiency to petitioner on May 12, 1995, for the 1987 taxable year (the 1995 notice of deficiency). During all relevant periods, petitioner was a cash-basis taxpayer. During 1986, petitioner purchased an interest in certain computer equipment for $135,000 cash and a note for the balance of his $1,000,000 purchase price. The equipment was then leased to a third party. Petitioner claimed deductible losses from the leasing of the computer equipment (the computer leasing deductions (CLDs)) in the following amounts: Year Amount 1986 $200,250 1987 321,002 1988 51,972Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011