Ronald W. Stewart - Page 3




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                                  FINDINGS OF FACT                                    
               Petitioner resided in Laurel Springs, New Jersey, at the               
          time of filing his petition and amended petition with this Court.           
          After filing his petition in this case, petitioner filed                    
          delinquent Federal income tax returns for each of the years in              
          issue.  The returns for 1992, 1993, 1994, and 1995 are dated                
          January 15, 1998, January 31, 1998, February 7, 1998, and                   
          February 23, 1998, respectively.  No requests for extensions of             
          time to file were requested or granted.                                     
               Petitioner's 1992 and 1993 tax returns claim capital loss              
          carryover deductions emanating from a nonbusiness bad debt                  
          incurred in 1990.  The capital loss carryovers claimed in 1992              
          and 1993 are $3,000 and $788,2 respectively.  Petitioner's tax              
          return for the 1994 year does not claim any capital loss                    
          carryforward.  Petitioner's tax returns show tax liabilities in             
          the following amounts:                                                      
                    Years                                                             
          1993       1994       1995                                                  
               Amount:   $15,594    $15,787    $25,113                                
          Petitioner had taxes withheld from his wages for each of the                
          years in issue.  The amounts withheld for the years 1993 through            
          1995 are as follows:                                                        




               2All amounts have been rounded to the nearest dollar.                  




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