Henry A. Julicher - Page 3




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          allocation of a portion of the purchase price to his basis in the           
          depreciable property.                                                       
               Whether petitioner is entitled to certain bad debt                     
          deductions under section 166 claimed on his 1994 return.  We hold           
          that he is not.                                                             
               Whether petitioner is entitled to a tax return filing status           
          of “married filing jointly” for the year in issue.  We hold that            
          he is not.                                                                  
               Whether petitioner is liable for an addition to tax and                
          accuracy-related penalty as determined by respondent.  We hold              
          that he is.                                                                 
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.  We           
          incorporate by this reference the stipulation of facts and                  
          attached exhibits.  At the time of filing the petition,                     
          petitioner resided in Wayne, Pennsylvania.                                  
          Petitioner’s Businesses                                                     
               Petitioner owned 100 percent of an S corporation, Julicher             
          Sports Facilities (Julicher Sports).  Julicher Sports engaged in            
          the business of constructing sports facilities, with emphasis on            
          surfaces such as tennis courts, weight room floors, artificial              
          turf for football fields, ice-skating rinks, etc.  In addition,             
          petitioner leased real property to Julicher Sports and to Rose              
          Weinstein, both discussed in greater detail below.                          






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Last modified: May 25, 2011