- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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