Melvin D. Lee - Page 2

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               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the year in issue, and              
          all Rule references are to the Tax Court Rules of Practice and              
               After settlement or concession of some issues, the two                 
          primary issues for decision are (1) whether petitioner has                  
          substantiated increased itemized deductions for State and local             
          income taxes, a $25,990 net operating loss (NOL) carryforward               
          from 1996, a $206,881 long-term capital loss carryforward from              
          1996, $35,289 in suspended passive activity losses in 1992                  
          through 1996 relating to real estate which petitioner sold in               
          1997, and $40,466 in legal fees relating to an investment in a              
          limited partnership, and (2) whether a nonbusiness loan made by             
          petitioner to a friend became worthless in 1997.                            

                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
               At the time the petition was filed, petitioner resided in              
          San Francisco, California.                                                  
               Petitioner provides consulting services to developers and              
          contractors seeking building permits.  Petitioner has invested in           
          various construction projects in the San Francisco Bay area.                

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Last modified: May 25, 2011