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MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge: Respondent determined a Federal income tax
deficiency for petitioner’s tax year ended December 31, 1995, in
the amount of $37,537. Respondent also determined an addition to
tax for said year of $5,631, pursuant to section 6651(a)(1).
The issues for decision are:
(1) Whether petitioner sustained an abandonment loss during
tax year ended 1995 that qualifies as a deductible loss pursuant
to section 165; and
(2) whether petitioner is liable for the section 6651(a)(1)
addition to tax for failure timely to file an income tax return
for tax year ended 1995.
Unless otherwise indicated, all section references are to
sections of the Internal Revenue Code in effect for the year at
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
FINDINGS OF FACT
General Background
Some of the facts have been stipulated and are so found.
The stipulations of the parties, with accompanying exhibits, are
incorporated herein by this reference. At the time the petition
was filed in this case, petitioner’s principal place of business
was San Diego, California.
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