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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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Last modified: May 25, 2011