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C. 1989 and 1991
For the 1989 and 1991 taxable years, the Schedules C
submitted by petitioner reported gross sales in the respective
amounts of $711,728 and $541,005. After reduction for costs and
expenses, Bicycle Sport was shown as having earned a net profit
of $124,325 in 1989 and $77,258 in 1991. Respondent has accepted
these figures as representing petitioner’s net business income
for such years, due in part to a lack of complete records for
performance of a bank deposits analysis. Since petitioner has
never specifically addressed these years in his generalized
arguments to the Court, we likewise hold petitioner to the
amounts stated on his own returns.
III. Capital Gain
As a general rule, a taxpayer is required on the disposition
of property to report as capital gain the excess of the amount
realized on disposition over his or her adjusted basis in the
property. Sec. 1001. On petitioner’s 1989 and 1990 returns, he
reported capital gain from the sale of stock in the amounts of
$10,490 and $9,227, respectively. The attached Schedules D,
Capital Gains and Losses, each show a sales price equal to the
full amount reported as gain and neither reflect nor deduct
therefrom any “Cost or other basis”. At trial, however,
petitioner seemed to contend, albeit rather obliquely, that he
was entitled to offset his reported gains by some amount other
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