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6. Whether Gabriel is entitled to property tax deductions
in taxable years 1995 and 1996 in excess of those allowed by
respondent. We hold that he is not.
7. Whether Morhaf is entitled to a property tax deduction
in taxable year 1995. We hold that he is not.
8. Whether the underpayment of tax required to be shown on
Gabriel’s 1995 and 1996 Federal income tax returns is due to
negligence or to disregard of rules or regulations. We hold that
it is.
9. Whether the underpayment of tax required to be shown on
Morhaf’s 1995 Federal income tax return is due to negligence or
disregard of rules or regulations. We hold that it is.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by reference.
FINDINGS OF FACT
At the time petitions were filed for his 1995 and 1996
taxable years, Gabriel resided in Fremont, California. At the
time the petition was filed for his 1995 taxable year, Morhaf
resided in Foster City, California.
Petitioners are brothers who in August of 1983 emigrated from
Syria to the United States with their family (the Mahmoud Daya
family). Members of the Mahmoud Daya Family include petitioners'
father, Mahmoud Gabriel Daya (Mahmoud), petitioners' mother, Laila
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