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2. whether petitioners’ bases in their wholly owned S
corporation include loans made directly to the S corporation by
an unrelated lender;
3. whether gains that petitioners realized from certain
1986 land sales represent capital gains or ordinary income;
4. whether petitioners are entitled to net operating loss
carryback deductions for 1987 arising from liabilities that
their wholly owned S corporation incurred to a bank with respect
to the bank’s payments to a third party pursuant to a letter of
credit between the bank and the S corporation;
5. whether petitioners are liable for additions to tax
pursuant to section 6651(a)(1) for failure to file timely income
tax returns for taxable years 1986 and 1987;
6. whether petitioners are liable for additions to tax for
fraud pursuant to section 6653(b) for taxable years 1986, 1987,
and 1988;
7. whether Jimmy and Sandra Morris (the Morrises) are
liable for additions to tax pursuant to section 6661 for taxable
years 1986 and 1987; and
8. whether Franklin Briggs (Briggs) is liable for
additions to tax pursuant to section 6661 for taxable years
1986, 1987, and 1988.
For purposes of order and clarity, after a brief
description of general background, each of the issues submitted
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