Syed Mohammad Jameel Hasan - Page 2

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          1990 and 1991, and (2) whether petitioner is entitled to a                  
          foreign tax credit of $55 for taxable year 1990.                            
               When called for trial, the parties did not call any                    
          witnesses or present any evidence, but they offered a stipulation           
          of facts and requested the Court to set dates on which to file              
          briefs.  The stipulation of facts and the attached exhibits are             
          incorporated herein by this reference.  Petitioner resided in               
          Cheney, Washington, at the time the petition was filed in this              
               For the years in issue, petitioner listed his occupation as            
          a college professor in his 1990 and 1991 Federal income tax                 
          returns.  In 1988, petitioner had purchased limited partnership             
          interests in Intelligent Systems - Master Limited Partnership               
          (Intelligent Systems), a partnership that was publicly traded on            
          the American Stock Exchange.  Intelligent Systems, a company that           
          designs, manufactures, and markets microcomputer-related                    
          products, had converted from a corporation to a master limited              
          partnership on December 31, 1986.  The master limited partnership           
          was subsequently converted back to a corporation on November 29,            
          1991.  In 1990 and 1991, petitioner's share of the net ordinary             
          losses suffered by Intelligent Systems was $28,666 and $20,340,             
          respectively.  Petitioner deducted these losses on his 1990 and             
          1991 Federal income tax returns.                                            

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