- 2 -
All section references are to the Internal Revenue Code in effect
for the years in issue, and all Rule references are to the Tax
Court Rules of Practice and Procedure.
After concessions,1 the issues for decision are:
(1) Whether petitioner failed to report wage income from
Flair Agency, Inc. (Flair), for the years 1990 and 1991 in the
amounts of $45,325 and $47,550, respectively; and
(2) whether petitioner may deduct net operating losses
(NOLs) for the years 1990 and 1991 in excess of the $13,935
allowed by respondent for the year 1990.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Judy Davis resided in
Edmond, Oklahoma, at the time the petition was filed. Ms. Davis
did not file individual Federal income tax returns and was
unmarried during the years in issue.2
1 Petitioner in her brief states: "Petitioner for the
primary purpose of resolving this matter at the trial court
level, temporarily concedes all issues set out in the Trial
Memorandum for Respondent filed with the Court on March 8, 1996
* * * except the following: [issues number 1 and 2 above]". As
petitioner in her brief does not otherwise contest respondent's
deficiency determinations or additions to tax and did not offer
any evidence at trial, we conclude that petitioner has conceded
the uncontested items. Money v. Commissioner, 89 T.C. 46, 48
(1987).
2 Unless otherwise indicated, all descriptions of
petitioner pertain to the 1990 and 1991 years.
Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011