- 7 -
1989 and 1990 Federal income tax returns can be summarized as
follows:
1989 1990
Gross Receipts $118,209 $33,422
Cost of Goods Sold ( 224,712) ( 51,733)
Gross Loss on
Securities ($106,503) ($18,311)
Loss on Futures
Contracts ( 117,852) 0
Net Operating Loss
Carryover 0 ( 80,067)
Total Claimed
Ordinary Losses ($224,355) ($98,378)
Petitioner continued to use the bid and asked method of
buying and selling securities during part of 1991, although he
ceased securities activities in that year because of his
accumulated losses. Petitioners reported all of their 1991
transactions in securities on Schedule D of their 1991 Federal
income tax return, claiming a net capital loss of $8,157.
Petitioners filed an application for automatic extension of
time to file their 1989 Federal income tax return extending their
time to file until August 15, 1990. However, the 1989 Federal
income tax return was not filed until April 15, 1992. The 1990
Federal income tax return was also filed on that date.
OPINION
In her notice of deficiency, respondent determined that the
securities and futures contracts purchased and sold by petitioner
during the taxable years 1989 and 1990 were capital assets within
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011