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In notices of deficiency,2 respondent determined the
following deficiencies in petitioner's Federal income taxes,
additions to tax, and penalties:
Additions to Tax Penalties
Year Deficiency Sec. 6651(a)(1)Sec. 6654(a) Sec. 6662(a)
1988 $3,132 $783.00 $200.08 --
1989 529 132.25 -- --
1990 1,764 441.00 116.00 --
1991 1,084 271.00 -- $217
1992 859 215.00 -- 172
1993 1,691 -- -- 338
Most of the adjustments in the notices of deficiency have
been settled by the parties. The settled issues and stipulated
facts are set forth in a Stipulation of Facts, a Stipulation of
Agreed Adjustments, a Second Stipulation of Agreed Adjustments,
and a Supplemental Stipulation of Facts. These settled
adjustments are not repeated here but are referred to, where
pertinent, in connection with the consideration of a disputed
issue. The disputed issues for decision are: (1) Whether
petitioner is entitled, for her 1988, 1989, and 1990 tax years,
to deductions for net operating loss carryforwards from her 1985,
1986, and 1987 tax years; (2) whether petitioner is entitled to
deductions for trade or business expenses for the years 1990,
1991, 1992, and 1993 in amounts greater than amounts that were
2
Respondent issued a separate notice of deficiency for each
of the years 1988, 1989, and 1990 and one notice of deficiency
for 1991, 1992, and 1993.
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