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(5) Is petitioner required to recognize for 1993 gain from
the sale of certain real property located at 287 Sanchez Street,
San Francisco, California (Sanchez Street property), in excess of
the amount that he reported? We hold that he is.
(6) Is petitioner entitled to deduct for each of the years
1991 and 1992 certain claimed Schedule E expenses? We hold that
he is not.
(7) Is petitioner liable for each of the years at issue for
the fraud penalty under section 6663(a)? We hold that he is not.
(8) Is petitioner liable for each of the years at issue for
the accuracy-related penalty under section 6662(a)? We hold that
he is.
(9) Is petitioner liable for 1993 for the addition to tax
under section 6651(a)(1)? We hold that he is.
The Court held the trial in this case on October 19, 1999.
At that trial, petitioner appeared pro se. Sometime after the
trial in this case, and before the posttrial briefs were due,
petitioner retained counsel. On December 16, 1999, petitioner,
through that counsel, filed, inter alia, a motion to open the
record in order to receive additional evidence (petitioner’s
motion). By Order dated March 31, 2000 (March 31, 2000 Order),
the Court granted petitioner’s motion and calendared a further
trial in this case to commence on August 21, 2000. The March 31,
2000 Order directed the parties in pertinent part, as follows:
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