- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011