- 2 - The issues that remain for our consideration are: (1) Whether petitioners are entitled to claim a nonbusiness bad debt deduction for loans made to petitioner Barbara Jean Kidder’s (Mrs. Kidder’s) son; and (2) whether petitioners are liable for a late filing addition to tax for 1992 and/or an accuracy-related penalty for the 1992 and/or 1993 tax year. FINDINGS OF FACT1 Petitioners resided in Pebble Beach, California, at the time their petition was filed in this case. Petitioners filed a joint Federal income tax return for their 1992 and 1993 taxable years. With respect to their 1992 return, petitioners sought two extensions of time to file, the last of which extended the time to October 15, 1993. Petitioners’ 1992 return was executed by the return preparer on October 11, 1993, and by petitioners on October 14, 1993. The date stamp placed on petitioners’ 1992 income tax return, which would normally show when respondent received the return, is illegible. During the taxable years, Mrs. Kidder was employed as a manager and petitioner Warren J. Kidder (Mr. Kidder) was self- employed as an appraiser. Mrs. Kidder began advancing funds to her son, David Bogue (Mr. Bogue), in 1983. The advances were to pay for Mr. Bogue’s personal and business obligations. Some of 1 The stipulation of facts and the attached exhibits are incorporated by this reference.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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