- 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.
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