- 2 - 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 aidPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011