Richard D. Frazier and Yvonne Frazier - Page 2

                                        - 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              
               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