Christopher A. Boyko and Roberta A. Boyko - Page 2

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          6662(a) penalty of $2,661, for petitioners' 1991 taxable year.              
          Respondent has conceded that petitioners are not liable for the             
          section 6651(a)(1) addition to tax.  After further concessions,             
          the following issues remain for our consideration:  (1) Whether             
          petitioners are entitled to an ordinary or a capital loss                   
          deduction for funds expended in a business venture; (2) whether             
          petitioners are liable for an accuracy-related penalty under                
          section 6662 in the amount of $2,661.                                       
                                  FINDINGS OF FACT2                                   
               Petitioners, Christopher A. Boyko and Roberta A. Boyko, are            
          husband and wife and resided in Parma, Ohio, at the time their              
          petition was filed in this case.  Petitioners filed a joint                 
          return for the 1991 taxable year.  Roberta Boyko is a party to              
          this proceeding solely because she signed the joint return for              
          1991; consequently, Christopher Boyko is referred to herein as              
          petitioner.                                                                 
               Petitioner is a lawyer and has practiced law in Ohio since             
          1979.  Until June 1987, petitioner practiced in the law practice            
          of his father, Andrew Boyko.  Petitioner practiced in a variety             
          of areas, including personal injury, probate, and business law.             
          In June 1987, petitioner acquired his father's law practice, and            
          was subsequently elected to the office of Law Director for the              


               2The stipulation of facts and the attached exhibits are                
          incorporated by this reference.                                             




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