- 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
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