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Revenue Code, as amended, and all Rule references are to the Tax
Court Rules of Practice and Procedure.
The issues to be decided are as follows:
(1) Whether petitioners may deduct a loss related to the
alleged abandonment of real property by Searcy M. Ferguson’s
(petitioner) bankruptcy estate;
(2) whether petitioners may deduct a loss related to the
alleged theft of a diamond ring by petitioner’s former wife;
(3) whether petitioners may deduct a loss related to the
alleged failure of petitioner’s former wife to assume the
obligation of liens that attached to real property awarded to her
pursuant to an agreement incident to divorce;
(4) whether petitioners may deduct a loss related to the
alleged failure of petitioner’s former wife to pay taxes on real
property awarded to her pursuant to an agreement incident to
divorce;
(5) whether petitioners are liable for a section 6651(a)(1)
addition to tax for failure to file timely; and
(6) whether petitioners are liable for a section 6662
accuracy-related penalty.
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Last modified: May 25, 2011