- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007