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Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
After concessions,1 the issue for decision is whether
petitioner is entitled to deductions and/or losses in amounts
greater than those allowed by respondent for the years in issue.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The deemed admissions, the stipulation of facts, and the attached
exhibits are incorporated herein by this reference. At the time
he filed the petition, petitioner resided in Pound Ridge, New
York.
During the years in issue, petitioner was a senior executive
of a merchant bank in Australia, president of a New York
investment company, and an underwriter with Lloyd’s of London
(Lloyd’s).
1 Petitioner admitted and stipulated the income amounts
determined by respondent in the notice of deficiency. See Rule
91. The only variation is that the notice of deficiency
determined petitioner realized pension income of $8,300 from
Fidelity and $22,410 from Smith Barney in 1994, whereas
petitioner admitted, and petitioner and respondent stipulated,
petitioner realized this income in 1992. Accordingly, a Rule 155
computation will be necessary.
Petitioner is deemed to have admitted that he is liable for
the additions to tax pursuant to secs. 6651(a)(1) and 6654 for
the years in issue. Rule 91(f).
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Last modified: May 25, 2011