- 2 -
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.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011