- 13 - Schedule C Deductions and Net Operating Loss Carryovers Pursuant to an extension of time, petitioner filed his 1992 Federal income tax return on October 15, 1993. Thereon he reported no salary or wage income. His Schedule C, however, reported business income of $317 as interest on a money market account. He also deducted $36,035 in business expenses, including $15,000 for “Telephone, Litigation Reputation, Professional Dues, Law Library, Software--Computer Publications”. On his 1992 return petitioner also claimed a net operating loss carryover of $34,797. Proceedings Before This Court The parties were notified that this case had been set for trial approximately 5 months before the trial date. In preparing for trial, respondent repeatedly wrote to petitioner, asking for records that would demonstrate his bases in the securities that had been held in the Kidder Peabody account and for records that would substantiate his deductions. Such records were not forthcoming. Nor did petitioner participate meaningfully in developing the case for trial. He delayed in meeting with respondent concerning the stipulation process and ultimately contributed efforts that were, at best, negligible. All evidentiary documents contained in the stipulation were obtained by respondent from either Kidder Peabody or the U.S. District Court for the Southern District of New York.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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