- 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