H. Dee Johnson, Jr. and Mary L. Johnson, n.k.a. Mary L. Alphin - Page 2

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                                 MEMORANDUM OPINION                                   

               HALPERN, Judge:  Respondent has determined deficiencies in             
          petitioners’ Federal income taxes of $22,297 and $13,179 for 1994           
          and 1995, respectively (the audit years).  The parties have                 
          settled or otherwise disposed of certain of the adjustments                 
          resulting in those determinations, and the only question                    
          remaining for decision is whether petitioner husband (petitioner)           
          has available for use by him in the audit years a claimed                   
          $153,000 net operating loss (NOL) derived from his bankruptcy               
          estate.                                                                     
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the audit years, and all            
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  
               This case was submitted for decision without trial.  See               
          Rule 122.  The parties have agreed to stipulate certain facts               
          (the stipulation).  The stipulation, with attached exhibits, is             
          incorporated herein by this reference.  We shall not here                   
          repeat the stipulation or recite the contents of the attached               
          exhibits.  We shall, however, summarize certain facts as an aid             










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