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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.
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