Carl W. and Barbara H. Patterson - Page 2

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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             

          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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