- 2 -
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.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011