- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011