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In 2000 and 2001, respectively, Wells Fargo withdrew $54,736
and $71,157 from PGI’s bank account in repayment of principal due
on the $197,050 Wells Fargo loan. The record herein does not
indicate whether PGI defaulted on this loan or whether Wells
Fargo called upon petitioner to make payments on the PGI loan
under his personal guarantee.
On or about June 26, 2001, petitioner and his wife timely
filed their joint 2000 Federal income tax return. On their 2000
joint Federal income tax return, petitioner and his wife did not
attach a Schedule D, Capital Gains and Losses, and no capital
loss for 2000 was claimed thereon.
For 2001, petitioner and his wife did not file a timely
Federal income tax return.
On March 5, 2004, respondent mailed a notice of deficiency
to petitioner with respect to petitioner’s 2001 Federal income
tax liability.
On April 2, 2004, after receiving the above notice of
deficiency, petitioner and his wife untimely filed a 2001 joint
Federal income tax return, on which return petitioner and his
wife reported various items of income and claimed various
deductions, including the $192,046 long-term capital loss
carryover from 2000 at issue herein.
On their 2001 Federal income tax return, petitioner and his
wife provided no explanation as to why the $192,046 long-term
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