Jerry J. and Susan N. LeBouef - Page 1

                                 T.C. Memo. 2001-261                                  

                               UNITED STATES TAX COURT                                

                    JERRY J. AND SUSAN N. LEBOUEF, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 15785-99.                  Filed October 3, 2001.           

                    R determined a deficiency for Ps’ 1993 taxable                    
               year based primarily on disallowance of:  (1) Amounts                  
               claimed for cost of goods sold with respect to a sole                  
               proprietorship and (2) a loss claimed with respect to a                
               partnership interest.                                                  
                    Held:  Ps have failed to overcome their initial                   
               reporting of $244,270 as gross receipts from their sole                
               proprietorship and, for lack of substantiation, are not                
               entitled to offset such receipts by an identical amount                
               for cost of goods sold.                                                
                    Held, further, Ps are not entitled to deduct a                    
               loss of $19,791 allegedly attributable to their                        
               interest in a partnership.                                             
                    Held, further, Ps are liable for the sec.                         
               6651(a)(1), I.R.C., addition to tax for failure timely                 
               to file their 1993 income tax return.                                  

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