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regarding this claimed activity. Since petitioner did not file
tax returns for the years at issue, and since there is no factual
agreement in the stipulation with regard to this activity, the
Court holds that petitioner is not entitled to deductions for a
trade or business activity for any of the years at issue.
Respondent is sustained on this issue.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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Last modified: May 25, 2011