- 2 -
all Rule references are to the Tax Court Rules of Practice and
Procedure.
After a concession,1 the issues to be decided involve
petitioners' entitlement to business bad debt deductions claimed
by them for certain payments made by petitioner Eric L. Jones
(petitioner) during the year in issue.
FINDINGS OF FACT
Some of the facts have been stipulated for trial pursuant to
Rule 91. The parties' stipulations of fact are incorporated
herein by reference and are found as facts in the instant case.
At the time they filed their petition in the instant case,
petitioners resided in Dublin, Georgia. During the taxable year
in issue, petitioner was an attorney licensed to practice law in
the State of Georgia.
Petitioner invested in real estate in order to create the
opportunity for his law firm to earn income by performing real
estate syndications, title searches, and loan closings. During
the taxable year in issue, however, petitioner was not involved
in the business of lending money or in the business of selling
corporations that he had created, funded, or promoted.
1 In the opening brief, respondent conceded that "there are no
additions to the tax applicable in this case" and made no
argument as to the accuracy-related penalty pursuant to sec.
6662. Accordingly, we consider the penalty to have been
conceded.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011