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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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