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(2) the reduction of net operating loss carryovers from
years preceding the years in issue to reflect income attributable
to contracts for deed executed in those prior years.
Additionally, the parties have agreed that a third issue,
the availability of depreciation deductions for properties
subject to such contracts for deed, is dependent upon and will be
resolved by our decision regarding petitioners’ accounting
method. The parties have stipulated the amounts to be allowed as
depreciation deductions in the event of a ruling either for
petitioners or for respondent.
Unless otherwise indicated, all section references are to
sections of the Internal Revenue Code in effect for the years in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
Background
This case was submitted fully stipulated pursuant to Rule
122, and the facts are so found. The stipulations of the
parties, with accompanying exhibits, are incorporated herein by
this reference. Petitioners resided in Moultrie, Georgia, during
each of the years in issue and at the time their petition was
filed in this case.
Formation of Greenville Insurance Agency (GIA)
Petitioner James W. Keith is a radiologist, and petitioner
Laura L. Keith is a dentist. Mrs. Keith is also the owner of a
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