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S corporation administrative adjustment, stating, with respect to
1991, that respondent had increased Trinity's ordinary income by
$233,661 and disallowed its $2,028,750 casualty loss in full.
Following petitioner's concession of the correctness of
respondent's adjustment to Trinity's ordinary income, we must
decide whether Trinity may deduct the casualty loss. We hold it
may not. Unless otherwise stated, section references are to the
Internal Revenue Code in effect for the year in issue. Rule
references are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulated
facts and the exhibits submitted therewith are incorporated
herein by this reference. Trinity was incorporated in 1988 and
elected subchapter S status as of January 1, 1989. It filed a
1991 Form 1120S, U.S. Income Tax Return for an S Corporation, on
September 15, 1992. At all times relevant herein, its principal
place of business was on property (the Property) located at 130
Trinity Meadows Lane, Willow Park, Texas. The Property consists
of four tracts of land measuring 99.916 acres, 33.597 acres, .6
acres, and 69.391 acres, respectively. Two rivers run along or
through the Property's borders.
Trinity's original shareholders purchased the Property on
March 6, 1987, intending to develop it for parimutuel racing,
which would later be legalized in the State of Texas. At the
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