- 2 -
James P. Shea and Patricia H. Shea, docket No. 2860-96
Penalty
Year Deficiency Sec. 66621
1992 $244,224 $48,485
Christopher M. and Kim A. Shea, docket No. 2861-96
Penalty
Year Deficiency Sec. 6662
1992 $47,945 $9,589
Because these cases present common questions of fact and law,
they were consolidated for purposes of trial, briefing, and
opinion and hereinafter will be referred to in the singular.
The issues for decision are as follows:
(1) Whether certain expenditures deducted by petitioners on
Schedules C of their 1992 Federal income tax returns were
incurred in a trade or business within the meaning of section
162;
(2) alternatively, whether petitioners are entitled to
deduct all or any part of the losses claimed--
(a) as theft losses arising from a transaction entered
into for profit under section 165(c)(2),
(b) as theft losses under section 165(c)(3),
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. For convenience, all monetary amounts are rounded to
the nearest dollar.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011