Oliver W. and Edna D. Wilson - Page 2




                                        - 2 -                                         
               Penalty                                                                
                    Year     Deficiency      Sec. 6662(b)(1)                          
                   1992      $19,181            $3,836                               
                   1993       24,707             4,941                               

          Petitioners filed a petition to redetermine the deficiency and              
          penalty for 1993 and a second petition to redetermine the                   
          deficiency and penalty for 1992.  We consolidated these cases for           
          purposes of trial, briefing, and opinion pursuant to Rule 141(a)1           
          because they present common questions of fact and law.  For                 
          convenience, these cases hereinafter are referred to as this                
          case.                                                                       
               After concessions,2 the issues for decision are as follows:            
               (1) Whether petitioners are entitled under section 162(a) to           
          deductions claimed on Schedules C, Profit or Loss From Business,            
          for 1992 and 1993 with respect to a purported                               
          restaurant/nightclub business and, if so, in what amounts;                  
               (2) whether petitioners are entitled under section 167 to              
          deduct depreciation expenses claimed with respect to two                    





               1Unless 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.                                                                  
               2Respondent concedes that 25 percent of the building                   
          petitioner Oliver W. Wilson owned at 5401-9 S. Broadway was                 
          placed in service and used for rental purposes during 1991, 1992,           
          and 1993.                                                                   




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