- 7 - 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 267,257 166,687Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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