Harvey L. Hoover - Page 3

                                        - 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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