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Addition to Tax Penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1989 $1,363,638 $340,560 $272,728
1990 303,274 -- 60,655
1991 237,234 60,864 47,447
The issues in this case, Iranian bad debt and domestic
issues, have been bifurcated for separate resolution. This
opinion addresses the domestic issues.
After concessions by the parties,2 the sole issue for
decision is whether certain payments received by petitioners
pursuant to a sale agreement for the sale of real property should
be included in gross income in the year received.
This issue was submitted by the parties fully stipulated.
This reference incorporates herein the stipulation of facts and
attached exhibits. At the time they filed their petition,
petitioners resided in Huntington Beach, California.
FINDINGS OF FACT
Sale Agreement
On November 1, 1989, Doris and Ferydoun Ahadpour as sellers
entered into an “Agreement for Purchase and Sale of Real Property
and Escrow Instructions” (Agreement) with buyer Coultrup
Development Co. (CDC). Pursuant to the Agreement, petitioners
agreed to sell certain improved real property known as
2 The parties filed a Stipulation of Settled Issues with
this Court on Apr. 17, 1998, resolving all domestic issues except
for the issue before this Court. Furthermore, the parties agree
that additions to tax under sec. 6651(a)(1) and accuracy-related
penalties under sec. 6662(a) shall not apply to the domestic
issues for all years at issue.
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