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Unless otherwise specified, section references are to the
Internal Revenue Code in effect for the years in issue, and Rule
references are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioner resided in Maryland when he filed the petition.
A. Petitioner’s Business
Petitioner was the sole proprietor of JFC Excavating in
1987-90. Petitioner bought the following excavating equipment:
Purchase Purchase
Date Description Price
Oct. 14, 1983 Terex TS14B, Ser. $84,500.00
No. 69699
Nov. 26, 1984 Caterpillar 953LGP, 88,500.00
Ser. No. 20Z355
Oct. 16, 1986 Case 1835, Ser. No. 14,561.65
17168653
Petitioner sold these three pieces of equipment (the three pieces
of equipment) and 58 other pieces of excavating equipment in
1987-90.
B. Petitioner’s Tax Years 1981-86
Petitioner’s tax years 1981-86 were at issue in Allnutt v.
Commissioner, T.C. Memo. 1991-6 (Allnutt I), affd. without
published opinion 956 F.2d 1162 (4th Cir. 1992). We dismissed
Allnutt I to the extent it related to issues on which petitioner
had the burden of proof because petitioner failed to state a
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