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petitioner is entitled to the following deductions claimed at
trial and framed by her as (a) $733,500 for the theft loss of a
pension, (b) $225,000 as carryforward legal expenses, (c) a
$142,482 investment loss on a condominium and lot in Florida, (d)
a $42,500 investment loss on a Simbari painting, (e) a $561,375
carryforward business or investment loss on rare coins, and (f) a
$125,403 carryforward business or investment loss on historical
documents.
Some of the facts were stipulated, and those facts, with the
annexed exhibits, are so found and are incorporated herein by
reference. At the time the petition was filed, petitioner's
legal residence was Minnetonka, Minnesota.
Petitioner was previously married to Michael W. Blodgett
(Mr. Blodgett). She was no longer married to Mr. Blodgett at the
time of trial, and the record is unclear as to the date of their
divorce. During the year at issue, petitioner was employed as a
teacher by the Minneapolis public school system. Her filing
status in 1998 was head-of-household.
Mr. Blodgett has a doctoral degree in educational
administration. In the 1970s, he founded a business, T.G.
Morgan, Inc. (the business), which bought and sold rare coins.
The business began as a sole proprietorship but was incorporated,
with a subchapter S election, in 1985. During 1992, petitioner
was a 27.5 percent owner of the business. Mr. Blodgett also
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