-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.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