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The issue for decision is whether petitioners are entitled
to claimed capital loss carryover deductions relating to a 1995
purported sale of residential property located in Honolulu,
Hawaii.
Unless otherwise specified, references to petitioner in the
singular are to petitioner Michael R. Joseph, and all section
references are to the Internal Revenue Code in effect for the
years in issue.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time the petition was filed, petitioners resided in
Honolulu, Hawaii.
From 1987 to 1992, petitioner practiced as a chiropractor in
California but once a month commuted to Hawaii as a consultant
for insurance companies. In 1992, petitioners sold their
California residence, and petitioner moved his family and his
chiropractic practice to Hawaii.
On December 21, 1992, with proceeds from the sale of their
California residence, petitioners purchased a residential lot
located at 595 Kahiau Loop, Honolulu, Hawaii (the property), for
a purchase price of $662,608.
At the time of purchase, petitioners intended to construct
on the property their personal residence. The property has
unobstructed views of Diamond Head and the Pacific Ocean, with
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