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Federal income tax (tax):
Accuracy-Related
Year Deficiency Addition to Tax Penalty
1995 $12,112 $0.00 $2,308.60
1996 12,050 602.35 2,410.00
1997 28,819 2,881.40 5,763.80
1998 16,671 0.00 3,334.20
1999 19,665 0.00 3,933.00
The only issue remaining for decision is whether the appli-
cation of section 469 to petitioner’s claimed partnership losses
for the respective years at issue violates the Due Process Clause
of the Fifth Amendment to the Constitution of the United States.
FINDINGS OF FACT
All of the facts in this case, which the parties submitted
under Rule 122, have been stipulated by the parties and are so
found.2
Petitioner resided in Jericho, New York, at the time he
filed the petition in this case.
Petitioner practiced law as a tax attorney for decades,
specializing in providing legal services to developers of real
property, including low-income apartment complexes similar to
those purchased and operated by the partnership in which peti-
2In violation of Rule 143(b), petitioner alleges on brief
various facts (petitioner’s alleged facts) not stipulated by the
parties and not otherwise supported by the record in this case.
In further violation of that Rule, petitioner attached to his
opening brief various documents (petitioner’s documents) that are
not part of the record and that the Court had returned to peti-
tioner. We shall not rely on petitioner’s alleged facts or
petitioner’s documents.
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