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After concessions,1 the issues for decision are: (1)
Whether petitioners are required to recognize and report gains
resulting from their disposition of various partnership
interests; (2) whether petitioners are entitled to bad debt
deductions for alleged loans from their wholly owned corporation
to various partnerships; (3) whether petitioners are liable for a
tax on a distribution received in 1987 from an individual
retirement plan (IRA); (4) whether petitioners are liable for tax
on their excess contributions to an IRA during 1987; (5) whether
petitioners are liable for an addition to tax pursuant to section
6651(a)(1)2 for failure to file timely their 1987 return; (6)
whether petitioners are liable for additions to tax pursuant to
section 6653(a)(1)(A) and (B); and (7) whether petitioners are
liable for an addition to tax pursuant to section 6661.
1Respondent concedes that: (1) $34,574 of losses disallowed
in the notice of deficiency is properly deductible; (2) there
were no unreported gains in the amount of $8,421 from the sale of
stocks; and (3) there is an unreported loss of $336 from
petitioners' sale of stock funds.
Petitioners concede that: (1) $188,957 of losses disallowed
in the notice of deficiency is not deductible in 1987; (2)
unreported rental income of $5,133 must be included as income in
1987; (3) they failed to report interest income of $1,711, which
must be included in 1987; and (4) they received an IRA
distribution of $1,830, which they failed to report as income on
their 1987 Federal income tax return.
2Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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