- 2 - $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, petitionerPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011