J. Clark and Mary R. Bundren - Page 2




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               After concessions, the primary issues for decision are:                
               1.  The adjusted basis of a rental property located at 3435            
          South 116th East Avenue in Tulsa, Oklahoma (the 116th East Ave.             
          property), immediately after petitioners acquired it in a section           
          1031 like-kind exchange in 1994.  Determination of this issue is            
          dispositive of the depreciation deduction allowable with respect            
          to the property for taxable year 1995 and of the amount of loss             
          petitioners realized on their sale of the property in taxable               
          year 1996; and                                                              
               2.  whether for taxable years 1995 and 1996, petitioners are           
          liable for accuracy-related penalties pursuant to section                   
          6662(a).                                                                    
               Section references are to the Internal Revenue Code in                 
          effect for the relevant tax years.  Rule references are to the              
          Tax Court Rules of Practice and Procedure.                                  
                                  FINDINGS OF FACT                                    
               The parties have stipulated some of the facts, which are so            
          found.  The parties’ stipulation of facts and the associated                
          exhibits are incorporated herein by this reference.                         
          Petitioners                                                                 
               At all times relevant to this proceeding, petitioners were             
          married.  J. Clark Bundren is a medical doctor practicing in the            
          fields of obstetrics/gynecology and infertility.  When                      
          petitioners filed their petition, they resided in Tulsa,                    
          Oklahoma.                                                                   




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