Woody F. Lemons - Page 2

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             Woody F. Lemons, Docket No. 16562-90                                     
                                     Additions to Tax                                 
                                     Sec.          Sec.        Sec.                   
             Year     Deficiency     6653(a)(1)    6661(a)     6651                   
             1986     $230,650       1$11,533      $57,663     --                     
             1987     19,071            1954       4,768       --                     
             1988     7,138          357           1,785       --                     
                                                                                     
             Paula S. Lemons, Docket No. 16799-90                                     
                                     Additions to Tax                                 
                                     Sec.          Sec.        Sec.                   
             Year     Deficiency     6653(a)(1)    6661(a)     6651                   
             1986     $195,644       1$9,782       $48,911     --                     
             1987     16,284            1814       4,071       --                     
             1988     14,139         1,246         3,535       $995                   

                  1Plus 50 percent of the interest due with respect to                
             the portion of the underpayment attributable to negligence.              

             All section references are to the Internal Revenue Code as               
             in effect during the years in issue.                                     
                  After concessions, the issues for decision are:                     
             (1) Whether petitioners are entitled to an ordinary loss or              
             to a capital loss due to the fact that eight memberships in              
             the Moonlight Beach Club, Inc., owned by Mr. Lemons became               
             worthless in 1986; (2) whether petitioners are entitled to               
             deduct, as an ordinary and necessary business expense under              
             section 162(a), the annual dues which Mr. Lemons allegedly               
             paid in 1986 to the Moonlight Beach Club, Inc., by reason                
             of his ownership of the eight club memberships; (3) whether              
             petitioners' deductions of losses from various partnerships              
             in 1987 and 1988 should be disallowed; (4) whether                       




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