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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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