Stephen P. Arnold - Page 2

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          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.                                  




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