Sidney C. Shaw - Page 2




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          The issues presented are:  (1) Whether losses claimed by                    
          petitioner are subject to the passive activity loss limitations             
          under section 469 and (2) whether petitioner is liable for the              
          accuracy-related penalty under section 6662(a).  Unless otherwise           
          indicated, all section references are to the Internal Revenue               
          Code in effect for the years in issue.                                      
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.                   
          Petitioner resided in Stillwater, Oklahoma, at the time of filing           
          the petition.  He owned real estate investment properties,                  
          interests in various business entities, gasoline-hauling                    
          trailers, and an airplane.                                                  
               Petitioner researched properties and operational businesses.           
          He developed a business model and consulted with his banker,                
          construction supervisor, and operations managers.  He either                
          purchased the property individually or purchased the property               
          indirectly through an entity in which he held an ownership                  
          interest.  Petitioner then developed the land, renovated the                
          existing building, or inventoried the property for future                   
          development.  Petitioner leased many of his properties to Shaw’s            
          Gulf, Inc. (Shaw’s Gulf), or its affiliates, and Shaw’s Gulf                
          managed the day-to-day business operations.                                 








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Last modified: May 25, 2011