William Barry Blythe and Cheryl Lynn Blythe - Page 2




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               (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-           

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