Judy Davis - Page 7

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            amount conceded by respondent.4  Consequently, we sustain                                    
            respondent's disallowance.                                                                   
                  In reaching all of our holdings herein, we have considered                             
            all arguments made by petitioner and to the extent not mentioned                             
            above find them to be irrelevant or without merit.                                           
                  To reflect the foregoing,                                                              
                                                             Decision will be entered                    
                                                       under Rule 155.                                   

























                  4  Respondent's notice of deficiency allowed petitioner a                              
            NOL deduction of $13,935 for the 1990 taxable year.  Respondent                              
            has conceded the NOL deduction allowed in the notice of                                      
            deficiency.                                                                                  



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