- 2 - 2. Held, further, P is entitled to deduct his 1999 net loss from purchases and sales of securities to the extent of $3,000. Secs. 165(f), 1211(b)(1), I.R.C. Frank Chen, pro se. Paul T. Butler and Lindsey D. Stellwagen, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION HALPERN, Judge: By notice of deficiency mailed to petitioner on October 15, 20021 (the notice), respondent determined a deficiency in petitioner’s 1999 Federal income tax of $611,357 and additions to tax totaling $252,093. On brief, respondent concedes the additions to tax. As a result of an agreement between the parties, the only issue remaining for decision is whether petitioner’s net loss of $84,794 from the purchase and sale of securities during 19992 is, for that year, deductible in full, or, pursuant to a limitation applicable to capital losses, only to the extent of $3,000. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for 1999, and all Rule 1 Because of administrative error, the notice of deficiency was dated Oct. 15, 2003. 2 We assume from the stipulation of the parties that the net loss of $84,794 was realized upon actual sales of the securities in question.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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