Nicholas M. Romer - Page 7




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                                       OPINION                                        
         A.   Aviation Expenses                                                       
              Petitioner concedes that he failed to report gross receipts             
         in the amounts determined in respondent’s notice of deficiency.              
         He contends, however, that he is entitled to deduct associated               
         business expenses not claimed on his returns for the subject                 
         years.  He claims that these newly asserted deductions more than             
         offset the gross proceeds that he omitted from his returns and               
         that consequently he has no deficiency for any year in issue.                
              The parties have stipulated that petitioner is entitled to              
         certain deductions not claimed on his return with respect to both            
         his aviation activities and the Romer & Co. accounting                       
         business.6  Giving effect to the parties’ concessions and                    
         stipulations results in net losses from petitioner’s aviation                
         activities for each of the years in issue but indicates positive             
         net income from petitioner’s other activities.  Seeking to                   
         eliminate any remaining net income (and indeed to produce                    
         significant net losses) from his accounting business and other               


               6 Respondent concedes that petitioner is entitled to the               
          following Schedule C deductions (including depreciation), which             
          were not claimed on petitioner’s Federal income tax returns:                
                                   Romer &             Aviation                       
                    Year           Co.                 Activities                     
                    1989           $ 99,805            $ 75,049                       
                    1990           119,106             91,646                         
                    1991           267,257             166,687                        





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