Wallace R. Noel and Robinette Noel - Page 3

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               (1) Whether any of the amount received from PepsiCo, Inc.              
          (PepsiCo), on the sale of petitioner's1 stock in Pizza Manage-              
          ment, Inc., is excludable from petitioners' income under section            
          104(a)(2).  We hold that $295,461 is excludable.                            
               (2)   Whether legal fees and other expenses should have been           
          included in the basis of petitioner's stock in Pizza Management,            
          Inc., sold in 1990.  We hold that $219,000 of the fees should               
          have been so included.                                                      
               (3)  Whether petitioner substantiated amounts included in              
          the basis of his failed investment in a T.J. Cinnamons Bakery               
          franchise.  We hold that the amounts have not been substantiated.           
               (4)  Whether petitioners are entitled to deduct the invest-            
          ment interest expense claimed on their 1990 Federal income tax              
          return related to loans from the United Bank of Fort Collins (the           
          bank).  We hold that they are, in the amounts set out herein.               
               (5)  Whether 1991 deductions claimed for attorney's fees               
          have been substantiated by petitioners.  We hold that the fees              
          have not been substantiated.                                                
               (6)  Whether petitioners are subject to the accuracy-related           
          penalty under section 6662(a) in connection with the filing of              
          their 1990 and 1991 Federal income tax returns.  We hold that               
          they are not.                                                               

          1All references to petitioner are to Wallace R. Noel.                       

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