- 2 - 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.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