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petitioners resided in Grand Haven, Michigan. Roger G. Cotner
is, and was during the year in issue, a practicing attorney. He
has been a member of the bar of this Court since 1982.
References to petitioner are to Marlan W. Cotner.
Petitioners filed a joint Federal income tax return for the
year 1990 on or about October 18, 1991. After completion of
respondent's audit and during the preparation of the notice of
deficiency, which was issued on August 18, 1994, petitioners
submitted to respondent a Form 1040X, Amended U.S. Individual
Income Tax Return, dated July 12, 1994. The Form 1040X contained
an amended Schedule D claiming a long-term capital loss.
Roger G. Cotner prepared petitioners' original return as well as
the Form 1040X. Petitioners now concede the adjustments made in
the notice of deficiency. In their petition, however,
petitioners raise the issue of whether they are entitled to the
capital loss deduction claimed on their amended return.
During the year in issue petitioner worked as a self-
employed artist and as indicated, Roger G. Cotner was employed as
an attorney. Petitioner has apparently had a lifelong interest
in horses and horseback riding. She began riding horses in the
third grade. She purchased her first horse while she was
attending college as an art major. Her particular interest is in
dressage riding, a form of riding in which the horse is required
to execute a variety of precision movements upon command from its
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