- 3 - 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 itsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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