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DAVID TAYLOR ENTERPRISES, INC. v. COMMISSIONER

Dkt. No. 7698-03.

89 T.C.M. 1369 (2005)

T.C. Memo. 2005-127

David Taylor Enterprises, Inc. & Subsidiaries v. Commissioner.

United States Tax Court.

May 31, 2005.

Attorney(s) appearing for the Case

Lawrence Sherlock and Juan F. Vasquez, Jr., for petitioner;

Derek B. Matta, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

KROUPA, Judge:

Respondent determined deficiencies of $431,1141 for 19992 and $113,390 for 2000 in petitioner's Federal income taxes. The issue to be decided is whether losses realized on the sale of classic cars during the years at issue are capital or ordinary losses under section 1221(a).3 Resolution of this issue depends on whether...

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