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Held, further, P failed to follow the procedures
necessary to claim low-income housing tax credits.
Held, further, statements made by R’s
representative at a bankruptcy plan confirmation
hearing did not waive R’s determination that P owes
income taxes for 1997.
Alphonse Mourad, pro se.
Steven M. Carr, for respondent.
RUWE, Judge: Respondent determined a $189,745 income tax
deficiency for petitioner’s 1997 tax year. The issues presented
to the Court are: (1) Whether petitioner should be taxed on gain
from the sale of assets by his S corporation during the
corporation’s bankruptcy proceeding; (2) whether petitioner is
entitled to low-income housing tax credits; and (3) whether
respondent waived his claims for payment of petitioner’s 1997
income tax.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts, the second stipulation of facts, and
the accompanying exhibits are incorporated herein by this
reference.1 At the time the petition was filed, petitioner
resided in Massachusetts.
1Respondent objected to many of the exhibits on the basis of
relevancy and/or hearsay. Even if we accept those exhibits, they
would have no effect on our findings of fact or the outcome of
this case.
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