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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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