Vernon Miller - Page 5




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            also used the services of Mr. Patterson in selling petitioner’s                            
            direct or indirect interests in four radio stations.  Petitioner                           
            financed one of those sales, having received six notes from the                            
            purchaser in connection with that financing.                                               
                  Petitioner filed Form 1040, U.S. Individual Income Tax                               
            Return (return), for 1993, the year at issue, in which he re-                              
            ported, inter alia, taxable interest income of $47,211 and                                 
            dividend income of $23.  Petitioner’s 1993 return included:                                
            (1) Schedule C, Profit or Loss From Business (Schedule C), which                           
            showed a $3,810 loss from an appliance repair business;                                    
            (2) Schedule D, Capital Gains and Losses (Schedule D), which                               
            showed total short-term capital losses of $28,039 and total long-                          
            term capital losses of $70,000; (3) Schedule E, Supplemental                               
            Income and Loss (Schedule E), which showed total rental real                               
            estate income of $113,103 and total partnership losses of $295;                            
            and (4) Form 4797, Sales of Business Property (Form 4797), in                              
            which petitioner claimed a loss of $109,482 from the sale or                               
            exchange of property used in a trade or business.  The $109,482                            
            loss claimed in Form 4797 related to the Miller loan and included                          
            expenditures that he made in connection with recovering that                               
            loan.  The basis of the property for which petitioner claimed a                            
            loss in Form 4797 was listed in that form as $212,029.  Peti-                              
            tioner also reflected the $109,482 loss that he claimed in that                            
            form as “Other gains or (losses)” on page 1, line 15, of his 1993                          






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Last modified: May 25, 2011