Glenn H. and Diane J. Flood - Page 2




                                        - 2 -                                         
               The issues for our consideration are:  (1) Whether                     
          petitioners’ 1991, 1992, and 1993 income was underreported in the           
          amounts of $28,195, $22,695, and $74,013, respectively; (2)                 
          whether petitioners are entitled to a 1992 bad-debt deduction               
          under section 166;1 (3) whether petitioners are entitled to a               
          1992 casualty loss deduction under section 165; (4) whether                 
          petitioners’ 1992 gain from the sale of Glenwood Wrecker Service            
          was understated in the amount of $10,635; and (5) whether                   
          petitioners are liable for the accuracy-related penalty under               
          section 6662(a) for the 1991, 1992, and 1993 tax years.                     
                                  FINDINGS OF FACT2                                   
               When their petition was filed, petitioners Glenn H. and                
          Diane J. Flood resided in Chatsworth, Georgia.  Glenn H. Flood              
          (petitioner) owned two businesses during the years in question,             
          Flood’s Auto Parts (FAP) and Glenwood Wrecker Service (Glenwood).           
          FAP                                                                         
               During the tax years in issue petitioner owned and operated            
          FAP, a sole proprietorship located in Chatsworth, Georgia.  FAP             
          consisted of the wholesale and retail sale of auto parts, a                 
          wrecker service, and the sale of junk cars to a scrap metal                 

               1 Unless otherwise indicated, all section references are to            
          the Internal Revenue Code in effect for the taxable periods under           
          consideration, and all Rule references are to the Tax Court Rules           
          of Practice and Procedure.                                                  

               2 The parties’ stipulation of facts and exhibits is                    
          incorporated herein by this reference.                                      




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