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Respondent originally determined a deficiency in
petitioner's Federal income tax of $12,126 for 1998. Respondent
subsequently moved for and was granted leave to file an answer
out of time. In the answer, respondent asserted an increased
deficiency of $20,430 for 1998.
Although respondent disallowed for 1998 certain business
expense deductions on Schedule C, Profit or Loss From Business,
petitioner offered no evidence and made no argument on the issue.
Petitioner has therefore conceded the issue. See, e.g., Bradley
v. Commissioner, 100 T.C. 367, 370 (1993); Sundstrand Corp. v.
Commissioner, 96 T.C. 226, 344 (1991). The issue remaining for
decision is whether petitioner is entitled to claim for 1998 a
net operating loss deduction carryforward from 1996.
The stipulated facts and exhibits received into evidence are
incorporated herein by reference. At the time the petition in
this case was filed, petitioner resided in Springtown, Texas.
Background
Petitioner filed a Federal income tax return for 1996 with a
Schedule C in the business name of "Bell <Amore Italian Bistro".
The schedule reported on line 31 a net loss of $76,989.
Petitioner, on her Form 1040, U.S. Individual Income Tax Return,
line 12, reported the same amount, $76,989, as her business loss.
Both total income and adjusted gross income were reported on
lines 22 and 31 as negative $68,713.
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