- 2 - Steven B. Bass, for respondent. PARR, Judge: Respondent determined deficiencies in petitioners' Federal income tax for taxable years 1988 and 1989 in the amounts of $387 and $40,482, respectively. In the answer, respondent asserted that petitioner is liable for an addition to tax pursuant to section 6662(a).1 After concessions, the issues for decision are: (1) Whether for 1989 petitioners realized $571,179 on the foreclosure sale of certain real property or a lower amount which represents the property's fair market value. We hold petitioners realized a lower amount which represents the property's fair market value. (2) Whether for 1989 petitioners are liable for the accuracy- related penalty pursuant to section 6662(a). We hold they are not. Some of the facts have been stipulated and are so found. The stipulated facts and the accompanying exhibits are incorporated herein by this reference. At the time the petition in this case was filed, petitioners resided in Austin, Texas. FINDINGS OF FACT Petitioners owned real property located at 3501 Dime Circle in Austin, Texas (the Dime Circle property). The Dime Circle 1 All section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated. References to petitioner are to Richard D. Frazier. All dollar amounts are rounded to the nearest dollar.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011