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Penalty
Petitioners Docket No. Year Deficiency Sec. 6662(a)
Richard J. and 8792-95 1987 $49,074 None
Eileen L. Salem 1990 19,179 $2,487
Robert S. and 8793-95 1990 7,202 None
Bernice S. Saxon
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
We must decide the following issues:
(1) Whether, under section 1366, petitioners Richard J.
Salem and Bernice S. Saxon have sufficient basis from which to
deduct losses incurred by Salem, Saxon & Nielsen, P.A., an S
corporation;
(2) whether petitioner Richard J. Salem realized gain of
$59,224 upon the distribution of real property from Gulf
Properties of Pinellas County, Florida III, Inc., an S
corporation; and
(3) whether, if such gain was realized, petitioners Richard
J. Salem and Eileen L. Salem were negligent in failing to report
it.
FINDINGS OF FACT
Some of the facts have been stipulated, and they are so
found. The stipulation of facts and the exhibits attached
thereto are incorporated herein by this reference.
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