- 6 -
incurred by Capital Growth Fund, an S corporation,3 and passed
through to petitioners as the sole shareholders. Petitioner
listed Capital Growth Fund's business activity as "investment
company" on Capital Growth Fund's 1995 Form 1120S, U.S. Income
Tax Return for an S Corporation. Capital Growth Fund did not
earn any income for 1995. Petitioners also calculated short-term
capital losses of $7,543. They claimed total Schedule D short-
term capital losses for 1995 of $3,000 pursuant to the section
1211(b) limitation.
Petitioners listed their two children as dependents and
claimed exemptions for them. Apparently, respondent has no
disagreement with these two additional exemption deductions.
Respondent asserted a claim for an increased deficiency in
petitioners’ 1995 Federal income tax pursuant to section 6214(a)
in the Answer to Second Amended Petition filed on April 20, 1998.
Respondent seeks to increase the deficiency by $13,711 on the
basis of a computational error. Respondent contends that the
correct deficiency for 1995 on the basis of adjustments to gross
income set forth in the notice of deficiency is $17,625 and not
$3,914. As previously stated, in the notice of deficiency
2(...continued)
record, and it probably resulted from a mathematical error by
petitioners.
3 Petitioners elected to make Capital Growth Fund an S
corporation on Aug. 28, 1995.
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011