Robert E. Corrigan - Page 3

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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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