Ferydoun Ahadpour, a.k.a, F. Ahadpour, And Doris Ahadpour - Page 2




                                        - 2 -                                         
          The Court agrees with and adopts the opinion of the Special Trial           
          Judge, which is set forth below.                                            
                         OPINION OF THE SPECIAL TRIAL JUDGE                           
               NAMEROFF, Special Trial Judge:  Respondent determined                  
          deficiencies in petitioners’ Federal income taxes, additions to             
          tax, and penalties as follows:                                              
                                   Addition to Tax        Penalty                    
             Year     Deficiency    Sec. 6651(a)(1)      Sec. 6662(a)                 
             1989     $1,363,638       $340,560           $272,728                    
             1990        303,274           --               60,655                    
             1991        237,234         60,864             47,447                    
               Some of the issues in this case were severed for separate              
          resolution and resolved in Ahadpour v. Commissioner, T.C. Memo.             
          1999-9.                                                                     
               The issues for decision herein are:  (1) Whether petitioners           
          are entitled to a claimed business bad debt deduction; (2)                  
          whether petitioners are entitled to deduct legal expenses of                
          $30,000 in 1990 and $30,025 in 1991; (3) whether petitioners are            
          liable for the accuracy-related penalty for all years at issue;             
          and (4) whether petitioners are liable for additions to tax under           
          section 6651(a)(1) for 1989 and 1991.                                       
               Some of the facts have been stipulated, and they are so                
          found.  The stipulations of facts and the attached exhibits are             
          incorporated herein by this reference.  At the time they filed              
          their petition, petitioners resided in Huntington Beach,                    
          California.                                                                 





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