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deficiency in docket no. 18097-97 reflects a deficiency of
$24,654 in the 1992 Federal income tax liability of petitioner
and Nora J. Banks. By way of an amendment to the answer in
docket no. 18096-97, respondent disallowed deductions of $108,306
including a net operating loss (NOL) carryover of $101,365 that
petitioner applied to 1988 and alleged a resulting additional
deficiency of $10,596 for that year. Respondent also alleged in
the amended answer that petitioner was liable for a $5,576
addition to his 1988 tax under section 6651(a)(1).1
Following the parties’ concessions, including one by
respondent that Nora J. Banks has no deficiency for 1992 because
she qualifies for relief from joint liability on a joint return
under section 6015, we must decide:
1. Whether petitioner’s gross income includes any of the
settlement proceeds which he received from an action based, in
part, on Title VII of the Civil Rights Act of 1964 (title VII),
Pub. L. 88-352, 78 Stat. 253;
2. Whether petitioner may deduct an NOL in any of the
subject years;
3. Whether petitioner’s 1992 gross income includes the
items of income discussed below;
1 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years in issue. Rule
references are to the Tax Court Rules of Practice and Procedure.
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