2 Accuracy-related Addition to tax penalty Year Deficiency Sec. 6651(a)(1) Sec. 6662(a) 1991 $57,187 $15,064 $11,437 1992 129,170 19,577 25,834 After concessions,1 the issues for decision are: 1. Whether the Court's denial of petitioner's second motion for a continuance was proper. We hold that it was. 2. Whether petitioner's documentary evidence was properly excluded from evidence after he failed to comply with the Court's orders and his agreement with respondent to identify in writing and exchange that evidence with respondent. We hold that it was. 3. Whether petitioner may deduct more Schedule C and Schedule E expenses for 1991 and 1992 than respondent allowed. We hold that he may not. 4. Whether petitioner may deduct investment interest expense for 1992. We hold that he may not. 5. Whether petitioner failed to report $18,795 in capital gain for 1992. We hold that he did. 6. Whether petitioner failed to report gain of $122,000 from the sale of the Brentwood Apartments in 1992. We hold that he failed to report gain of $118,000. 1 Petitioner concedes that respondent properly disallowed $9,883 of Olga Schaefer's Schedule C business expenses for 1991, and that he failed to report interest and dividend income of $936 for 1992.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011