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Year Deficiency
1993 $148,920
1994 78,684
1995 280,384
1996 62,439
After concessions, the issues for decision are: (1) Whether
a preliminary change of ownership report filed with the
Sacramento County Assessor’s Office is admissible; (2) whether
petitioners may take a deduction for an abandonment loss; (3)
whether petitioners must report income from cancellation of
indebtedness with regard to advances received; (4) whether
petitioners may deduct expenses incurred on work performed on the
roofs of their shopping centers; (5) whether petitioners may
deduct real estate taxes paid; and (6) whether petitioners may
deduct payments made to Royal Roofing, Inc., and Consolidated
Electrical Distributors.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time they filed
their petition, George Tsakopoulos (hereinafter, petitioner) and
Drousoula Tsakopoulos resided in Carmichael, California.
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Last modified: May 25, 2011