B. Suri - Page 2

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          $6,215.  Respondent concedes that petitioner is not liable for              
          the addition to tax under section 6651(a)(2) or under section               
          6654.                                                                       
               The issues for decision are whether petitioner is entitled             
          to a deduction under section 166 for a bad debt loss in 1999;               
          whether petitioner is entitled to an interest expense deduction             
          under section 163; whether petitioner is liable for the addition            
          to tax for failure to file under section 6651(a)(1); and whether            
          a penalty should be awarded to the United States under section              
          6673 by reason of petitioner’s failure to exhaust his                       
          administrative remedies.                                                    
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the year in issue, and              
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
                                     Background                                       
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.                   
          Correspondence and communications between the parties are set               
          forth in respondent’s motion to compel production of documents              
          and motion under section 6673.  Petitioner resided in New York,             
          New York, at the time that he filed his petition.                           
               Petitioner was not in a trade or business during 1999 but              
          received income as a result of investments.  In 1999, petitioner            






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