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proper disposition of petitioner’s motion. See Rule 232(a)(2).
We therefore decide the matter before us based on the record that
has been developed to date.
Background
Petitioner resided in Knoxville, Tennessee, at the time that
the petition was filed with the Court.
For the relevant periods involved herein petitioner owned
stock in several businesses, including White Pine Truck & Trailer
(White Pine), Tamperproof Identification Company, Inc.
(Tamperproof), Identrol Corporation (Identrol), and Barbour Hill
Bakery (Barbour Hill).
By notice dated December 12, 1996, respondent determined a
deficiency in petitioner’s income tax in the amount of $47,9464
for the taxable year 1992 based on the following adjustments:
First, respondent determined that petitioner was not
entitled to claim a loss in the amount of $162,033 in connection
with White Pine based on the determination that White Pine was a
passive activity and that the passive activity loss from such
activity would be limited to passive income. In the alternative,
respondent determined that petitioner would not be entitled to
claim the $162,033 loss because petitioner had not established
any basis in his White Pine stock.
4 All monetary amounts are rounded to the nearest dollar.
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