James H. Upchurch, (1996)
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James H. Upchurch, (1996)
T.C. Memo. 1996-441
UNITED STATES TAX COURT JAMES H. UPCHURCH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 14784-88. Filed September 26, 1996.Robert E. Kovacevich, for petitioner.James W. Clark and Keith Medleau, for respondent.MEMORANDUM FINDINGS OF FACT AND OPINION GERBER, Judge: Respondent determined deficiencies in, additions to, and increased interest on Federal income tax for petitioner's 1980, 1981, 1982, and 1983 taxable years as follows:Additions to Tax Sec. Sec. Sec. Year Deficiency 6653(a) 6653(a)(1) 6653(a)(2) 1980 $4,176 $209 --- ---1981 5,373 --- $269 11982 5,335 --- 267 11983 2,573 --- 129 1 Additions to Tax Increased Interest Sec. Sec. Sec. Year 6659 6661 6621(c) 1980 $1,253 --- 21981 1,612 --- 21982 1,601 3$1,333.75 21983 --- --- 2 Commissioner, T.C. Memo. 1990-640, affd. 1 F.3d 954 (9th Cir. 1993), control as to the income tax deficiencies. In the aforementioned case it was decided that the taxpayer's energy device had a fair market value not in excess of $1,000 (the alleged purchase price was $80,000) and that the taxpayer was not entitled to deductions and credits because his object was "solely to gain a significant tax advantage and not to earn an economic profit." Petitioner has conceded the income tax deficiencies in this case, which are based on a disallowance of $9,100 loss from Evergreen Partnership I (Evergreen) and investment tax credit carrybacks and...See the full content of this document
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