- 2 - Faramarz Elghanian Addition to Tax and Penalty Year Deficiency Sec. 6661, I.R.C. Sec. 6662(a), I.R.C. 1987 $1,867 1988 186,159 $46,540 1989 219,622 $43,924 Faramarz and Mitra Elghanian Year Deficiency 1990 3,949 1991 3,949 The issues for decision are: 1. Whether petitioner’s2 loss on the expropriation of his family’s Iranian property occurred in 1979, as respondent contends, or in 1986, as petitioners contend. We hold that it occurred in 1979. 2. Whether petitioner was a resident of the United States in 1979. We hold that he was not. 3. Whether petitioner is entitled to a settlement of his claimed deduction for expropriation losses on the same terms as respondent’s settlement with petitioner’s father and brother. We hold that he is not. 4. Whether petitioner is liable for the addition to tax under section 6661(a)3 for 1988 and the accuracy-related penalty 2 References to petitioner are to Faramarz Elghanian. 3 Section references are to the Internal Revenue Code as amended and in effect in the years in issue. Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011