T.P. and Najieh R. Crigler - Page 2




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               The issues for decision are:                                           
               1.  Whether petitioners may deduct an ordinary loss of                 
          $100,000 under section 1244 for loss in value of petitioner’s               
          FabuGlass stock in 1995.  We hold that they may not.                        
               2.  Whether petitioners are liable for the accuracy-related            
          penalty for negligence under section 6662 for 1995.  We hold that           
          they are.                                                                   
               Unless otherwise provided, section references are to the               
          Internal Revenue Code in effect for 1995, and Rule references are           
          to the Tax Court Rules of Practice and Procedure.  References to            
          petitioner are to Mr. Crigler.                                              
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          Petitioners resided in Chapel Hill, North Carolina, when they               
          filed their petition.                                                       
          A.   FabuGlass, Inc.                                                        
               1.   B.F. Lists, Inc.                                                  
               In 1981, petitioner incorporated B.F. Lists, Inc. (B.F.                
          Lists), in Arkansas to obtain, rent, and market mailing lists for           
          the retail sale of professional uniforms and accessories.                   
          Petitioner converted a rodeo arena in Conway, Arkansas, into a              
          mail order office, warehouse, and shipping facility (the Conway             
          premises) at a date not specified in the record.                            








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