- 2 - respectively.1 Following concessions and respondent’s assertion in the answer that petitioner is liable for an additional amount as to the addition to tax under section 6651(a)(1), we are left to decide: 1. Whether petitioner may use the filing status of “Married filing joint return”. We hold that he may not. 2. Whether petitioner realized losses on certain stock transactions. We hold that he did not. 3. Whether petitioner may deduct a loss of $86,889 from an S corporation named Only Kids, Inc. (Only Kids). We hold that he may not. 4. Whether petitioner may deduct certain itemized expenses in amounts greater than allowed by respondent. We hold that he may not. 5. Whether petitioner is liable for the additions to tax under sections 6651(a)(1) and 6654(a) included in the notice of deficiency and for the increase in the addition to tax under section 6651(a)(1) asserted by respondent in answer. We hold that petitioner is liable only for the amounts included in the notice of deficiency. 1 Unless otherwise indicated, section references are to the applicable versions of the Internal Revenue Code, Rule references are to the Tax Court Rules of Practice and Procedure, and dollar amounts are rounded to the nearest dollar.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011