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Accuracy-Related
Penalty
Year Deficiency Sec. 6662(a)
1995 $39,052 $7,810.40
1996 24,428 4,759.00
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years at issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
After concessions, the issues for decision are whether
petitioner: (1) Correctly computed his basis in a parcel of real
property he acquired and sold at a loss in 1995, or (2) in the
alternative, is entitled to a nonbusiness bad debt deduction in
1995 for a loan to petitioner’s daughter and her former
boyfriend.
We hold: (1) Petitioner overstated his basis and the
resulting loss on the sale of the property that he computed on
his return, and (2) is entitled to a nonbusiness bad debt
deduction.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and attached exhibits are incorporated
by this reference.
Petitioner resided in Foster City, California, when he filed
the petition in this case.
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Last modified: May 25, 2011