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The issues for decision are: (1) Whether petitioner is
entitled to section 179 expense and section 167 depreciation
deductions; (2) whether petitioner has sufficient basis in a
partnership entitling him to deduct partnership losses; and (3)
whether petitioner is liable for an accuracy-related penalty
pursuant to section 6662(a).
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. Contrary to the petition,
which indicated petitioner resided in Elizabethtown,
Pennsylvania, when the petition was filed petitioner resided in
Lincoln, California.
A. Petitioner’s Background
Petitioner graduated from college with a degree in political
science and accounting and subsequently pursued a master’s degree
in taxation and business administration. He did not complete the
graduate degrees. While working on his master’s in taxation,
petitioner was employed as a tax manager for Levin Rosenfeld in
Bedminster, New Jersey. A year later, he left Levin Rosenfeld
and moved to Ohio to work for Provident Nursing Homes as its
assistant controller. In January 1988, he began employment with
1(...continued)
rounded to the nearest dollar.
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