Robert E. Corrigan - Page 2

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          Rules of Practice and Procedure.  Respondent determined the                 
          following income tax deficiencies, penalties, and additions to              
          tax for petitioner’s 1987 through 1991 taxable years:1                      
               Year:            1987     1988     1989      1990      1991            
               Deficiency:    $374,201  $86,517  $105,165  $173,542  $40,337          
               Additions to tax                                                       
               and penalties                                                          
               under secs.:                                                           
               6651(a)(1)     58,840   11,931     8,710    41,598    5,997            
               6653(a)(1)(A)   15,607     ---       ---       ---      ---            
               6653(a)(1)     ---     3,755      ---       ---      ---               
               6653(a)(1)(B)     ---1      ---       ---       ---      ---           
               6653(b)(1)(A)   78,269     ---       ---       ---      ---            
               6653(b)(1)     ---    10,573      ---       ---      ---               
               6663     ---      ---     13,786    21,190   10,240                    
               6653(b)(1)(B)     ---2      ---       ---       ---      ---           
               6662(a)     ---      ---     13,828    30,571    5,337                 
                    1 50 percent of interest due on $280,318.                         
                    2 50 percent of interest due on $62,059.                          
               After concessions by the parties, the issues remaining for             
          our consideration are:  (1) Whether petitioner’s debt that was              
          forgiven as part of a settlement agreement is includable in                 
          petitioner’s 1990 income; (2) whether petitioner’s stock and                
          option trading activity was a trade or business entitling him to            
          claim ordinary losses and/or business deductions on a Schedule C,           
          Profit or Loss From Business; (3) whether petitioner’s capital              
          gains/losses for 1987, 1990, and 1991 were correctly reported;              
          (4) whether petitioner is entitled to deduct payments or                    


               1 Respondent also determined substantial understatement and            
          negligence additions to tax under former secs. 6661 and 6653(a)             
          for 1987 and 1988, respectively, and under sec. 6662(a) for 1989            
          through 1991 as an alternative position if the fraud penalty were           
          not sustained under sec. 6653(b) or sec. 6663 as the case may be.           





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