- 2 -
Scott M. Estill and Stephanie F. Long, for petitioners.
Richard D. D’Estrada, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge: Respondent determined a deficiency of
$2,474 in petitioners’ Federal income tax for 2001.
The issues for decision are:
(1) Whether petitioners are entitled to claim a tax credit
pursuant to sections 381 and 44 for their subscription to the
AdaCom program (program); and
(2) if petitioners are entitled to a credit for their
investment in the program, the proper valuation of the program.2
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time they filed
the petition, petitioners resided in Morrison, Colorado.
During the year in issue, petitioners subscribed to the
program, which was sold, sponsored, and administered by AdaCon
1 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
Procedure.
2 The parties also discussed deductions taken on
petitioners’ 2000 tax return. Petitioners’ 2000 tax year is not
before the Court. Accordingly, we do not address this issue.
Rule 13(a).
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011