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Additions to Tax
Year Deficiency Sec. 6651(a)(1)1 Sec.6654
1988 $58,987 $14,230 $3,626
1989 4,666 100 --
1992 123,520 30,880 5,389
The issues remaining for decision are:
(1) Should the determinations of respondent in the notice of
deficiency (notice) that the parties have not resolved be
sustained? We hold that they should.
(2) Is petitioner entitled for 1988 to a claimed loss for an
alleged investment? We hold that she is not.
(3) Is petitioner entitled for 1988 to increase her basis in
certain real property that she sold during that year? We hold
that she is not.
(4) Is petitioner entitled for 1992 to deduct approximately
one-half of certain mortgage interest that she paid during that
year in Schedule A and one-half of such interest in Schedule E?
We hold that she is not.
Some of the facts have been stipulated and are so found.
The stipulation of facts (stipulation) and the exhibits attached
thereto are incorporated herein by this reference.
Petitioner resided in Hesperia, California, at the time the
petition was filed.
1 All section references are to the Internal Revenue Code in
effect for the years at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
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Last modified: May 25, 2011