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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.
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