- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011