- 2 - (1) Are petitioners liable for 1994 for self-employment tax? We hold that they are not. (2) Are petitioners entitled for 1994 to the deductions that they are claiming? We hold that they are not. (3) Are petitioners liable for 1994 for the accuracy- related penalty under section 6662(a)? We hold that they are to the extent stated herein. FINDINGS OF FACT Some of the facts have been stipulated and are so found. Petitioners resided in Murrieta, California, at the time the petition was filed. At various times during the last four months of 1993 and the first six months of 1994, petitioner William Barry Blythe (Mr. Blythe) acquired title to ten parcels of residential real prop- erty (parcels), each of which was subject to an outstanding mortgage loan at the time he acquired title. He acquired such title without having paid any cash or having assumed any such loan. With respect to six of the ten parcels, Mr. Blythe ac- quired title within one-to-several months after a notice of default had been recorded on each such parcel by the holder of the outstanding mortgage loan thereon (lender). With respect to the remaining four parcels, the lender recorded a notice of default on each such parcel within two-to-several months after Mr. Blythe acquired title to each parcel. Mr. Blythe held title (1) to three of the ten parcels until the lenders foreclosed on them during 1994 and (2) to the remain-Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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