- 2 - consideration, and all Rule references are to this Court’s Rules of Practice and Procedure. Following concessions, the issues for our consideration are: (1) Whether petitioners are entitled to claim a short-term capital loss relating to a purported $65,000 loan to Grant MacCoon for 1988; (2) whether petitioners are entitled to a $76,087 long-term capital loss for purported investments in “Buck Sales” for 1988; (3) whether petitioners are entitled to $147,0001 in bad debt losses claimed for 1989; (4) whether petitioners overstated their 1988 capital gains by $36,000; and (5) whether petitioners are liable for the delinquency and negligence additions for 1988 and an accuracy-related penalty for 1989. Separate findings of fact and opinion are hereafter set forth with respect to each of the first four issues. Those portions of the stipulation of facts that pertain to a particular issue are incorporated by this reference in the findings of fact for the issue to which they relate. 1 Petitioners claimed $156,879 in deductions on their 1989 Federal income tax return, the entire amount of which was disallowed by respondent. Respondent has conceded that petitioners are entitled to deduct $6,500 of expenses. Of the $156,879 claimed, $147,000 was claimed as bad debt losses. Petitioners presented no evidence with respect to the $3,379 difference (between $150,379 and $147,000), and thus we treat this as a concession by petitioners. Theodore v. Commissioner, 38 T.C. 1011, 1041 (1962).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011