- 2 -
1993 22,226 1,514 4,445
1994 19,178 673 3,836
All section references are to the Internal Revenue Code for
the years in issue. All Rule references are to the Tax Court Rules
of Practice and Procedure.
The deficiencies herein generally relate to petitioners'
ownership and operation of a restaurant in Stanton, California.
The issues for decision are: (1) Whether a purported sale of a
restaurant (Stanton Mexicatessen) from petitioners to Suvanee
Eagatatt on September 15, 1993, should be recognized for tax
purposes, so that petitioners would be entitled to a capital loss
on the sale for that year; (2) whether petitioners properly
reported the income from the operation of Stanton Mexicatessen for
1992, 1993, and/or 1994; (3) whether petitioners are entitled to
deductions for investment interest expenses for 1992, 1993, and/or
1994; (4) whether petitioners are liable for additions to tax
pursuant to section 6651(a) for failure to timely file their tax
returns for 1992, 1993, and 1994; and (5) whether petitioners are
liable for accuracy-related penalties pursuant to section 6662 for
1992, 1993, and 1994.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The
stipulated facts are incorporated in our findings by this
reference.
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