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issues to be de

cided in these

cases are:

1. Whethe

r respondent vi

olated the automatic stay under

section 362 of

the Bankruptcy

Code2 by auditing petitioner’s

Forms 1040, U.S

. Individual In

come Tax Return, and issuing

notices of defi

ciency for 1994

, 1995, and 1996;

2. whethe

r petitioner’s

capital gain in 1994 on the sale of

a house in Warr

en, New Jersey,

determined by r

espondent;

  • -

    2-

was less than the $90,888

1994

$23,663

$4,732

1995

3,102

620

1996

7,515

1,503

After conc

essions by John

Weller Wood (petitioner),

1

the

Year

Deficiency

Accuracy-related penalty Sec. 6662(a)

1Petitioner concedes that:

for

1. real

For 1994, the amount allowable as an itemiz estate taxes is $12,835 as determined by re

rather than Deductions,

$24,389 as claimed on Schedule A, of the Form 1040, U.S. Individual

Itemiz Income

ed deduction spondent, ed

Tax Return;

2.

he is not entitled to deduct losses of $3,4

and $809 for 1995 from IDN Distributorship from Home Business Services;

or

$1,578

31 for 1994 for 1995

of

a

3.

for 1996,

Buick

LeSabre

the amount is $201 as

allowable as a loss fr determined by responde

than $19,233 as Property; and

reported

on

Form

4797,

Sales

of

Busi

om the sale nt, rather ness

tax

4. for

the statute 1994.

of

limitations

does

not

bar

ass

essment of

2Bankruptcy Code references are to 11 U.S.C.

(2000).

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