3
7. Whether petitioner may deduct a net operating loss from
his bankruptcy estate for 1991. We hold that he may not.
8. Whether petitioner is liable for additions to tax and
accuracy-related penalties under sections 6651(a)(1) and 6662(a)
for 1991 and 1992. We hold that he is.
Unless otherwise indicated, section references are to the
Internal Revenue Code. Rule references are to the Tax Court
Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioner
Petitioner lived in Las Vegas, Nevada, when he filed his
petition in this case. He is a graduate of the University of
California at Berkeley and the Georgetown University Law Center
in Washington, D.C.
B. 1981 Tenants' Suit
Petitioner has been a property manager, investor, and
attorney at all times relevant here. He is admitted to practice
law in California and Nevada. Around 1981, several hundred of
his tenants sued him for building code violations and personal
injuries. In 1986, a court not specified in the record entered a
$1,950,000 judgment against him. Of that amount, $300,000 was
compensatory damages and the remainder was punitive damages.
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