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