J. David Golub - Page 13




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          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.                                 





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