- 2 - Year Deficiency Accuracy-Related Penalty Sec. 6662(a) 1997 $218,137 $43,627.40 1998 190,706 38,141.20 1999 167,818 33,563.60 Following concessions by the parties, we are left to decide whether petitioner may for the respective years deduct net operating loss (NOL) carryovers of $726,572, $726,572, and $703,308.1 We hold he may not. Section references, unless otherwise indicated, are to the applicable versions of the Internal Revenue Code. Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT Some facts were stipulated and are so found. The stipulation of facts and the accompanying exhibits are incorporated herein by this reference. Petitioner resided in Pasadena, California, when his petition to this Court was filed. During 1978, 1979, and 1980, petitioner invested in the stock market primarily through the brokerage firm of Paine, Webber, Jackson & Curtis (Paine Webber). Douglas Osborne (Osborne), a Paine Webber employee, was petitioner’s stockbroker. 1 The record contains sufficient evidence indicating that respondent determined appropriately that petitioner was liable for the referenced accuracy-related penalties. See sec. 7491(c). Because petitioner’s brief is silent as to any issue concerning that determination, we treat petitioner as having conceded it in full. See Rybak v. Commissioner, 91 T.C. 524, 566 (1988); Money v. Commissioner, 89 T.C. 46, 48 (1987).Page: Previous 1 2 3 4 5 6 7 8 Next
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