Judy Davis - Page 2

                                                 - 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