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Respondent determined deficiencies in petitioner's Federal
income taxes for the taxable years 1995 and 1996 in the amounts
of $3,484 and $3,311, respectively, and accuracy-related
penalties under section 6662(a) in the amounts of $697 and $662,
respectively.
After a concession by petitioner,2 the issues remaining for
decision are as follows:
(1) Whether petitioner engaged in his meteorite and pyrite
collection activity for profit during 1995 and 1996. We hold
that he did not.
(2) Whether petitioner's net capital loss for 1995 should
be limited to $282, as opposed to $2,864 as claimed on
petitioner's Schedule D for that year. We hold that it should.
(3) Whether petitioner is liable for accuracy-related
penalties under section 6662(a) for 1995 and 1996. We hold that
he is.
Adjustments relating to the taxable amount of petitioner's
Social Security benefits for the years in issue are purely
mechanical matters, the resolution of which is dependent on our
disposition of the disputed issues.
2 Petitioner concedes that he received Social Security
benefits for the taxable year 1996 in the amount of $12,402.
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