- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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