- 2 -
1990 6,916 3,156 1,033
1991 7,232 -- 1,446
The issues remaining for decision are:2
(1) Is petitioner entitled for the years at issue to any
deductions claimed for charitable contributions? We hold that he
is not.
(2) Is petitioner entitled for 1990 and 1991 to any Schedule
C (Profit or Loss from Business) deductions claimed with respect
to TFC Engineering? We hold that he is not.
(3) Is petitioner entitled for 1989 to treat (a) certain
long-term capital losses from the sales of stocks as his losses,
(b) certain transactions as giving rise to nonbusiness bad debts,
and (c) certain stock as worthless? We hold that he is not.
2 Respondent determined in the notice of deficiency (notice)
that petitioner is not entitled to the deduction for wages and
salaries of $7,633 claimed in Schedule E (Supplemental Income and
Loss) (1991 Schedule E) of his 1991 U.S. individual income tax
return (return) and that, consequently, he is not entitled to the
"total loss" of $6,951 claimed in that schedule, but instead has
1991 Schedule E total income of $682. Petitioner concedes that
he is not entitled to a 1991 Schedule E deduction for wages and
salaries in the amount of $7,633 and that he does not have a 1991
Schedule E "total loss" of $6,951. However, he claims with
respect to his 1991 Schedule E (1) that, in addition to the other
expenses claimed in that schedule, he is entitled to deduct
expenses for (a) contract labor and (b) automobile and travel of
$595 and $60, respectively, and (2) that he has "total income" of
$26. In response to those claims, respondent states on brief:
"While respondent does not concede that petitioner is entitled to
rental expenses in the specific categories or in the specific
amounts now claimed, respondent will not dispute that petitioner
realized a Schedule E rental gain for 1991 in the amount of $26".
Since respondent does not dispute that petitioner has 1991 Sched-
ule E "total income" of $26, we shall not address petitioner's
contentions regarding the deductions to which he claims he is
entitled in arriving at that "total income" amount.
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