Terry O'Neal Styron - Page 9




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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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