Jesse S. Frederick - Page 3

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          capital gain, petitioner had not provided evidence of basis to               
          respondent before the issuance of the notice of deficiency, and              
          thus respondent’s determinations accounted for gross proceeds                
          from sales of capital assets.  Before the record in this case was            
          closed, petitioner presented evidence from which the parties were            
          able to stipulate petitioner’s cost basis in, and, where                     
          relevant, costs of sale of, almost all of the capital assets.                
          The parties likewise stipulated that petitioner received capital             
          gains in various amounts during the years in issue.                          
               We find that petitioner had income (and loss) in the                    
          following amounts during the years in issue, based on the fact               
          that petitioner has stipulated, admitted, or failed to dispute               
          respondent’s evidence with respect to those amounts:                         

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