James P. Shea and Patricia H. Shea - Page 2




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               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.                                                         




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