- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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