2
respondent contends, or $164,000, as petitioner contends. We
hold that petitioner’s basis was $5,000.
2. Whether petitioner is liable for additions to tax for
1995 for (a) failure to file an income tax return and (b) failure
to pay estimated tax. We hold that he is.
Unless otherwise specified, section references are to the
Internal Revenue Code as amended. 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.
A. Petitioner
Petitioner resided in Hercules, California, when he filed
the petition in this case. He was married in 1994 and 1995. In
1994, petitioner and his wife owned rental real estate properties
in Richmond, California. They claimed depreciation deductions
for these rental properties on their 1994 income tax return.
B. The Chevron Station
1. Purchase by Petitioner in 1988
In 1988, petitioner paid $65,000 to buy lease rights, tools,
equipment, office fixtures, accessories, inventory, and goodwill
related to, and the right to operate, a Chevron gas station
located at 2234 MacDonald Ave., Richmond, California. Petitioner
and the seller allocated the $65,000 purchase price to tools,
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