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Unless otherwise indicated, all section references are to
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.
After concessions, the primary issues for decision are:
(1) For 1991, whether $22,192 in interest income relating to a
bank certificate of deposit should be charged to petitioner;
(2) for 1994, the amount of gambling costs petitioner realized to
offset petitioner’s gambling income; and (3) whether petitioner
is liable for additions to tax under sections 6651(a)(1) and
6654.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
When the petition was filed, petitioner resided in Brooklyn,
New York.
During the years in issue, petitioner was an officer and
shareholder of Delta Realty Development Corp. (Delta Realty). In
1988, Delta Realty purchased a parcel of real estate located in
Newark, New Jersey, with the intention to renovate the building
located on the property. In order to purchase the real estate,
Delta Realty obtained a $2.5-million loan from Bank Leumi Trust
Co. of New York (Bank Leumi).
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Last modified: May 25, 2011