James F. McGuirl - Page 2




                                        - 2 -                                         
          agrees with and adopts the opinion of the Special Trial Judge,              
          which is set forth below.                                                   
                         OPINION OF THE SPECIAL TRIAL JUDGE                           
               PANUTHOS, Chief Special Trial Judge:  Respondent determined            
          a deficiency in petitioner's 1993 Federal income tax in the                 
          amount of $5,851 and additions to tax under sections 6651(a) and            
          6654(a) in the amounts of $1,462 and $2452, respectively.  In an            
          answer to an amended petition, respondent asserted an increased             
          deficiency in the amount of $22,844, and an increase in additions           
          to tax under sections 6651(a) and 6654(a) in the amounts of                 
          $5,430 and $905, respectively.  In an amended answer to the                 
          amended petition, respondent asserted an additional increase in             
          deficiency in the amount of $136,975, and an additional increase            
          in additions to tax under sections 6651(a) and 6654(a) in the               
          amounts of $34,525 and $5,711, respectively.  After concessions             
          by respondent, the deficiency in income tax remaining in dispute            
          is $25,366.  The additions to tax under sections 6651(a) and                
          6654(a) remaining in dispute are $6,061 and $1,015, respectively.           
          At the time of filing the petition, petitioner resided in                   
          Washington, D.C.                                                            
               The issues remaining for decision are:  (1) Whether                    
          petitioner is precluded from claiming a net operating loss                  
          carryover from 1987 and 1988 to 1993 in the amount of $114,000              
          (or any greater amount); (2) whether petitioner is subject to the           

               2    For convenience, all sums have been rounded to the                
          nearest dollar amount.                                                      


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