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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.
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