- 3 - under section 6662(a)? We hold that they are to the extent stated herein. Background This case was submitted fully stipulated. The facts that have been stipulated are so found. Petitioners’ mailing address was in Chignik, Alaska, at the time the petition was filed. In 1988, petitioner Roderick E. Carlson, whose occupation during the year at issue was commercial fisherman, and petitioner Jeanette S. Carlson purchased the fishing vessel Yantari (Yantari), a 44-foot seiner made of fiber glass that was built in 1982. They paid $202,451 for that fishing vessel, which included the engine. Petitioners financed their purchase of the Yantari by borrowing money (loan) from Seattle First National Bank (bank or Seattle First). As security for that loan, petitioners granted to the bank a so-called preferred marine mortgage inter- est (mortgage) in the Yantari. During 1992, petitioners became delinquent in making pay- ments to the bank on the loan. On February 8, 1993, when the unpaid principal balance of the loan was $137,142, the bank foreclosed on the Yantari, the Yantari was sold for $95,000 as part of that foreclosure, the proceeds from that sale were used to reduce the outstanding principal balance of the loan by $95,000, and the bank discharged the remaining $42,142 of thePage: 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