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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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