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Respondent determined deficiencies in petitioners' Federal
income taxes for the taxable years 1992 and 1994 in the amounts
of $1,234 and $5,262, respectively, as well as accuracy-related
penalties under section 6662(a) in the amounts of $68 and $175,
respectively.
After concessions by petitioners,2 the only issue for
decision is whether petitioners are entitled to capital loss
carryovers for the years in issue based on the sale of a
residential property. We hold that they are not.
FINDINGS OF FACT
Some of the facts have been stipulated, and are so found.
Petitioners resided in Gravois Mills, Missouri, at the time that
their petition was filed with the Court.
Petitioners are husband and wife. Prior to February 1991,
petitioners resided and owned real property in Thousand Palms,
California (the Thousand Palms Property). The Thousand Palms
Property included a single-family home, a work area (a 20-foot by
40-foot garage) used by petitioner Mr. Taylor in his construction
business, and a mobile home. These structures were located on a
1(...continued)
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
2 Petitioners have conceded the Schedule C adjustments for
the years in issue and the penalties under sec. 6662(a) relating
to these adjustments.
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