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brokerage commission rebates claimed for 1987 and 1988; (5)
whether petitioner is entitled to defer gain realized from the
1987 sale of a residence under section 1034 and, if not, the
amount of gain to be recognized; (6) whether petitioner is
entitled to deduct losses from a horse breeding activity for 1987
through 1991; (7) whether petitioner has shown that respondent’s
determination that petitioner failed to report certain items of
income was in error; (8) whether petitioner is entitled to
itemized deductions for interest expenses, casualty losses, and
employee expenses in excess of the amounts allowed by respondent;
(9) whether petitioner is entitled to dependency deductions for
his children and/or a personal exemption for his former wife;
(10) whether petitioner is liable for additions to tax and
accuracy-related penalties for negligence for 1987 through 1991;
and (11) whether petitioner is liable for additions to tax and
penalties for substantial understatements.
FINDINGS OF FACT2
Petitioner resided in Newport Beach, California, at the time
his petition was filed. Petitioner’s Federal income tax returns
for 1987, 1988, 1989, 1990, and 1991 were filed on December 20,
1988, October 9, 1990, November 17, 1990, February 26, 1993, and
2 The parties’ stipulation of facts is incorporated by this
reference.
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