- 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