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MEMORANDUM OPINION
HALPERN, Judge: Respondent has determined deficiencies in
petitioners’ Federal income taxes of $22,297 and $13,179 for 1994
and 1995, respectively (the audit years). The parties have
settled or otherwise disposed of certain of the adjustments
resulting in those determinations, and the only question
remaining for decision is whether petitioner husband (petitioner)
has available for use by him in the audit years a claimed
$153,000 net operating loss (NOL) derived from his bankruptcy
estate.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the audit years, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
This case was submitted for decision without trial. See
Rule 122. The parties have agreed to stipulate certain facts
(the stipulation). The stipulation, with attached exhibits, is
incorporated herein by this reference. We shall not here
repeat the stipulation or recite the contents of the attached
exhibits. We shall, however, summarize certain facts as an aid
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