- 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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