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Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.4
4 As noted supra note 3, there is a difference in the
evidence as to whether petitioner paid $53,500 or $53,000 for the
boat. Under either figure, petitioner sustained a loss, and,
since the loss is not deductible because it was realized from the
sale of a personal asset, the Court's disposition of the
principal issue alleviates the need for a finding of the amount
petitioner paid for the boat and a Rule 155 computation.
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Last modified: May 25, 2011