Linda Klyce - Page 2




                                        - 2 -                                         

          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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