- 3 -
petitioner received and failed to report interest income of
$3,069 in 1990, $3,153 in 1991, and $8,784 in 1992; (3) whether
petitioner is entitled to claim a loss of $31,000 in 1991 from
the sale of one of his farms; (4) whether petitioner had farm
expenses in amounts greater than allowed by respondent;2 (5)
whether petitioner is liable for additions to tax for fraud
pursuant to section 66633 for each of the years in issue; and (6)
whether the assessments for 1990, 1991, and 1992 are barred by
the statute of limitations.
After concessions by the parties, the issues for decision in
docket No. 4590-00L are: (1) Whether respondent’s Appeals
officer abused his discretion in sustaining the collection action
1(...continued)
farm income
Net unreported 160,260.81 108,648.21 103,840.81
ordinary farm
income
2 In the notice of deficiency, respondent determined that
petitioner had farm expenses of $25,969 in 1990, $14,826 in 1991,
and $27,524 in 1992. Respondent now acknowledges in the
stipulation that petitioner’s allowable farm expenses are $63,381
in 1990, $54,652 in 1991, and $55,388 in 1992.
3 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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