Shizuo George Kurata - Page 2

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                  Shari C. Mauney, J. Robert Cuatto, and Rick V. Hosler, for                          

                                        MEMORANDUM OPINION                                            

                  HALPERN, Judge:  By notice of deficiency dated January 26,                          
            1995, respondent determined a deficiency in, an addition to, and                          
            a penalty on petitioner's Federal income tax as follows:                                  
                                          Addition to Tax   Penalty Under                             
                  Year   Deficiency       Sec. 6651(a)(1)   Sec. 6662(a)                              
                  1989    $34,821         $8,276                  $6,964                              
                  Unless otherwise noted, all section references are to the                           
            Internal Revenue Code in effect for the year in issue, and all                            
            Rule references are to the Tax Court Rules of Practice and                                
                  The issues for decision are (1) the amount of gain realized                         
            by petitioner upon the sale of certain rental properties and                              
            whether petitioner is entitled to nonrecognition of that gain                             
            under section 1033(a), (2) whether petitioner is entitled to                              
            certain disallowed Schedule A deductions, and (3) whether                                 
            petitioner is liable for the addition to tax and penalty.  The                            
            parties have stipulated various facts, which we so find.  The                             
            stipulations of facts filed by the parties and accompanying                               
            exhibits are incorporated herein by this reference.  Although the                         
            issues for decision are principally factual, we need find few                             
            facts in addition to those stipulated by the parties.                                     
            Accordingly, we shall not separately set forth our findings of                            

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