- 6 - On March 16, 1991, petitioner traded an unimproved 5-acre parcel of land that he owned for Grand Video, a video rental business with a store located in Vancouver, Washington. The selling price for the business, which did not include the land or building in which the store was located, was $30,000. On his 1991 Federal income tax return, petitioner reported a $53,000 basis in the land and claimed a long-term capital loss of $23,000 as a result of the acquisition of Grand Video. Petitioner owned and operated Grand Video as a sole proprietorship from the date he acquired it throughout the years in issue. Grand Video’s store was typically open from 10:30 in the morning until midnight, 7 days a week. Initially, petitioner was the only person who worked in the store. He eventually hired employees to assist him. At first, petitioner paid his employees “under the table”; that is, in cash, without withholding for Federal and State income and employment taxes. He failed to file the requisite Federal and State employment tax forms until examined by State employment tax authorities. As a result of the State audit, petitioner was determined to be an unregistered employer from June 1993 through July 1995. He was fined $500, plus penalties and interest. Petitioner used unnumbered, duplicate receipts to track video rentals at Grand Video. When a video was rented,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