Ronnie O. and G. June Craft - Page 2

                                        - 2 -                                         
         Loss From Business, of their 2001 return, and (2) if petitioners             
         are entitled to deduct the expenses, whether the expenses are                
         subject to the 2-percent limitation contained in section 672 and             
         the limitation contained in section 68.                                      
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
         The stipulation of facts and the attached exhibits are                       
         incorporated herein by this reference.  At the time they filed               
         the petition, Ronnie O. Craft (petitioner) and G. June Craft,                
         husband and wife, resided in Garland, Texas.  G. June Craft is a             
         party because she signed the joint tax return.                               
               Petitioner is a 50-percent shareholder in Craft-Barnett                
         Investments, Inc. (Craft-Barnett), an S corporation which was                
         converted from a C corporation in 1994.  James M. Barnett                    
         (Barnett) is the other 50-percent shareholder of Craft-Barnett.              
         Both petitioner and Barnett, in their capacity as officers and               
         employees, received a salary of $50,000 from Craft-Barnett in                
         2001.                                                                        
               Petitioner is also a shareholder in Abilene Investment                 
         Properties, Inc., a family-owned S corporation.  In addition,                
         petitioner is a partner in the ROC Family Limited Partnership                
         (ROC FLP) along with his wife and children.  ROC FLP owned the               

               2  Unless otherwise indicated, all section references are to           
          the Internal Revenue Code (Code) in effect for the year in issue,           
          and all Rule references are to the Tax Court Rules of Practice              
          and Procedure.                                                              




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