Kent Jensen and Carol Jensen - Page 2

                                                - 2 -                                                 
                                                                 Accuracy-Related                    
                                          Addition to Tax         Penalty                             
                  Year   Deficiency     Sec. 6651(a)       Sec. 6662(a)                               
                                                                                                     
                  1988      $  502               --                     --                            
                  1989      4,148         $1,058                       --                            
                  1990       9,335        --                      $1,871                              

                  Unless otherwise indicated, all section references are to                           
            the Internal Revenue Code in effect for the years in issue, and                           
            all Rule references are to the Tax Court Rules of Practice and                            
            Procedure.  All references to petitioner are to Kent Jensen.                              
                  The issue for decision is whether petitioners are entitled                          
            either to a section 166 business bad debt deduction with respect                          
            to $128,841 that was transferred to petitioners’ closely held                             
            corporation or to a section 1244 ordinary loss deduction in the                           
            same amount with respect to the stock of petitioners’ closely                             
            held corporation.                                                                         

                                         FINDINGS OF FACT                                             
                  Some of the facts have been stipulated and are so found.                            
            When the petition was filed, petitioners resided in Centerville,                          
            Utah.                                                                                     
                  On July 23, 1984, petitioners organized K&C Industries (K&C)                        
            as a corporation to market and sell artificial fingernails.                               
            Petitioner served as president and treasurer of K&C, and Carol                            
            Jensen served as vice president and secretary of K&C.                                     
                  At the time of K&C's formation, petitioners contributed to                          
            K&C $5,882 in cash, office furniture, and a computer system.                              




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