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(1) Whether Loma Farms, Inc. (LFI), an S corporation owned
by petitioner Lucian T. Baldwin III (petitioner) that purportedly
owned and managed a 5,000-acre lakefront lodge property known as
Granot Loma, operated a trade or business within the meaning of
section 162 or conducted an activity “not engaged in for profit”
within the meaning of section 183;
(2) whether the duty of consistency or the doctrine of
equitable estoppel applies to bar petitioner’s contention that
Baldwin Aircraft Corp. (BAC) was not a valid S corporation during
the years at issue;
(3) if the duty of consistency or the doctrine of equitable
estoppel applies to bar petitioner’s contention, whether BAC
operated a trade or business within the meaning of section 162,
or whether BAC conducted an activity “not engaged in for profit”
within the meaning of section 183;
(4) whether deductions for lodging and travel expenses
claimed by Baldwin Commodities Corp. (BCC), for 1990, 1991, and
1992, are allowable under sections 162 and 274; and
(5) whether petitioner is liable for the additions to tax
and penalties determined by respondent.
1(...continued)
89 T.C. 46, 48 (1987).
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