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previously allowed amortization deductions, as respondent
contends.
FINDINGS OF FACT
Some of the facts have been stipulated for trial pursuant to
Rule 91. The parties' stipulations of fact are incorporated
herein by reference and are found as facts in the instant case.
Petitioners Bill L. and Patricia M. Spencer (collectively,
the Spencers), husband and wife, resided in Roswell, Georgia, at
the time they filed their petition in the instant case.
Petitioners Joseph T. and Sheryl S. Schroeder (collectively, the
Schroeders), husband and wife, resided in Melbourne Beach,
Florida, at the time they filed their petition in the instant
case. Sheryl Schroeder is the daughter of the Spencers.
Background
Mr. Spencer graduated from Ohio University during 1966 with
a major in accounting and minors in finance and taxation. While
living in Columbus, Ohio, he worked as a cost accountant for
several companies. During 1966, he moved to Miami, Florida,
where he worked as an accountant for an accounting firm, doing
primarily audit work and tax return preparation. By 1968, Mr.
Spencer began working as the comptroller for a real estate firm
known as the Alan Morris Co. (Alan Morris), where he later became
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