Dennis W. Stark - Page 2




                                        - 2 -                                         

          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
               After concessions, the issues for decision are: (1) Whether            
          Lakeview Automotive, Inc., an S corporation wholly owned by                 
          petitioner, is entitled to a deduction for a bad debt loss under            
          section 166 or, in the alternative, a theft loss under section              
          165; (2) whether Lakeview Automotive, Inc., is entitled to a                
          deduction for a claimed rental expense; (3) whether Lakeview                
          Automotive, Inc., is entitled to a deduction for legal fees                 
          incurred in defending a suit brought by a former shareholder;               
          (4) whether Lakeview Automotive, Inc., is entitled to deductions            
          for amounts expended for a fence gate, roof work, and computer              
          equipment; and (5) whether petitioner is liable for an accuracy-            
          related penalty under section 6662(b)(2).                                   
                                  FINDINGS OF FACT1                                   
               At the time the petition in this case was filed, Dennis W.             
          Stark (petitioner) resided in Harrison Township, Michigan.                  
          Petitioner was the president and sole shareholder of Lakeview               
          Automotive, Inc. (Lakeview), an automotive parts wholesaler.                
          Lakeview was originally formed as a partnership by petitioner's             
          father, William Stark (William), and William's brother-in-law.              
          Lakeview's operations were conducted from real property at 6841             


               1 Some of the facts have been stipulated and are so found.             
          We incorporate by this reference the stipulation of facts, the              
          supplemental stipulation of facts, and attached exhibits.                   




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011