- 2 -
Respondent determined a deficiency in petitioner's Federal
income tax for 1990 in the amount of $7,169.
After concessions by petitioner,2 the issue for decision is
whether petitioner's claimed loss is properly characterized as an
ordinary loss or a capital loss.
Some of the facts have been stipulated and are so found.
The stipulations of fact and attached exhibits are incorporated
herein by this reference. Petitioner resided in Niantic,
Connecticut, on the date the petition was filed in this case.
Petitioner has been an airline pilot for American Airlines
since October 1985. During and preceding the taxable year in
issue, he bid his flight schedule on a reserve basis which
required him to be "on call" 20 days per month but guaranteed him
10 days off per month. Reserve pilots are required to be
available to fly on short notice in the event of a pilot
scheduling problem. As long as he remained in his home locality
and carried a beeper or cellular phone by which he could be
contacted, petitioner was free to use his "on call" time as he
wished. Petitioner's actual flight time averaged 4 to 6 days per
month.
2 Petitioner concedes that he is not entitled to
dependency exemption deductions for his two daughters, Christy
and Jenna, for 1990. Petitioner also concedes that he received
and failed to report interest income in the amount of $13 during
1990.
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