Horace D'Angelo - Page 2

                                         -2-                                          
               1.  Whether the notice of deficiency is “arbitrary”.  We               
          hold it is not.                                                             
               2.  Whether petitioner may deduct a forgiven debt in the               
          amount claimed on his 1995 tax return.  We hold he may.                     
               3.  Whether petitioner was personally engaged in the trade             
          or business of developing industrial real estate.  We hold he               
          was.                                                                        
               4.  Whether petitioner may under section 162 deduct certain            
          legal expenses paid by him.2  We hold he may.                               
               5.  Whether petitioner may under section 162 or 212 deduct             
          certain office expenses paid by him.  We hold he may not.                   
                                  FINDINGS OF FACT                                    
               Some facts were stipulated.  The stipulated facts and the              
          accompanying exhibits are incorporated herein by this reference.            
          We find the stipulated facts accordingly.  Petitioner resided in            
          Rochester Hills, Michigan, when the petition was filed.                     





               1(...continued)                                                        
          Petitioner failed to advance any arguments as to this issue in              
          his brief.  Accordingly, we deem the issue abandoned.  Wilcox v.            
          Commissioner, 848 F.2d 1007, 1008 n.2 (9th Cir. 1988), affg. T.C.           
          Memo. 1987-225; Lunsford v. Commissioner, 117 T.C. 183, 187                 
          (2001); Nicklaus v. Commissioner, 117 T.C. 117, 120 n.4 (2001).             
               2 Unless otherwise stated, section references are to the               
          applicable versions of the Internal Revenue Code, Rule references           
          are to the Tax Court Rules of Practice and Procedure, and dollar            
          amounts are rounded to the nearest dollar.                                  





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