- 3 - We find the stipulated facts accordingly. Petitioner is a C corporation with a fiscal year ending on May 31. It specializes in the repair and painting of buildings in the State of Tennessee. Its mailing address was in Brighton, Tennessee, when its petition was filed. In 1992, petitioner was awarded a contract (contract) to repair and paint 1,500 service stations in California, Arizona, Nevada, Oregon, Washington, and Alaska. Petitioner began working on the contract in 1992 and purchased in and around California most of the trucks, automobiles, and other equipment (collectively, equipment) necessary to complete its work under the contract. The equipment was generally used property purchased at auction. In 1994, petitioner began storing on a lot (lot) in California some of the equipment that had become inoperable. The record does not indicate that petitioner documented the assets which it placed on the lot. On May 31, 1995, petitioner sold some of the equipment located on the lot for $30,000. Petitioner reported on its Federal income tax return for its 1995 taxable year that it had paid $360,728 for the equipment sold in that transaction, and it claimed a $199,408 loss with respect to the sale. Petitioner reported on the return that the assets sold in the transaction were “VARIOUS ASSETS–-CA” and did not otherwise identify those assets.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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