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After concessions,1 the issues for decision are: (1)
Whether petitioner is entitled to a $32,241 deduction for amounts
purportedly paid to Mark Tietig for use of his securities as loan
collateral in 1993; (2) whether Farm & Grove Realty, Co. (Farm &
Grove) earned income of $215,922 on the sale of 53 lots in 1990;
(3) whether petitioner had unreported capital gains of $57,531.25
in 1991; (4) whether petitioner is allowed a $179,937 net
operating loss carryforward deduction in 1993; (5) whether
petitioner is entitled to deduct $19,995 as a casualty loss in
1993; (6) whether petitioner is liable for the self-employment
tax under section 14012 for 1990, 1991, and 1993; (7) whether
petitioner is entitled to correcting entries relating to flow-
through income reported from a partnership in 1990 and a flow-
through loss reported from the same partnership in 1991; and
(8) whether petitioner is liable for the accuracy-related penalty
pursuant to section 6662(a) for the years 1990, 1991, 1992, and
1993.
For purposes of order and clarity, after a brief general
background, each of the issues submitted for our consideration is
set forth below with separate background and discussion.
1See appendixes A and B.
2Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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