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