- 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