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Respondent determined a deficiency in petitioners' Federal
income tax for the taxable year 1992 in the amount of $4,339.
The issue for decision is whether a certain loss, which
respondent concedes is deductible, was incurred in 1992 as
petitioners contend.
The amount of miscellaneous itemized deductions to which
petitioners are entitled is a mechanical matter, the resolution
of which is solely dependent on our disposition of the disputed
issue. See sec. 67(a).
FINDINGS OF FACT
Some of the facts have been stipulated, and they are so
found. Petitioners resided in Lynnwood, Washington, at the time
when their petition was filed with the Court.
Carl Patterson (petitioner) has been actively engaged in the
commercial real estate market for approximately 40 years.
In 1990, petitioner began to consider the possibility of
acquiring commercial real estate in Houston, Texas. As part of
his investigation of such property, petitioner learned that
Skylane Apartment Projects (Skylane Apartments) was for sale by
its owner, Darby Suiter (Mr. Suiter).
Petitioner requested and received from Mr. Suiter a picture
and outline of Skylane Apartments. Thereupon, petitioner began
2(...continued)
the Internal Revenue Code in effect for 1992, the taxable year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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