- 6 - are legion that individuals required by the Internal Revenue Code to file a return must file a return and pay tax. E.g., Bassett v. Commissioner, 67 F.3d 29, 31 (2d Cir. 1995), affg. 100 T.C. 650 (1993); Stubbs v. Commissioner, 797 F.2d 936, 938 (11th Cir. 1986); Steinbrecher v. Commissioner, 712 F.2d 195, 198 (5th Cir. 1983), affg. T.C. Memo. 1983-12; United States v. Chrane, 529 F.2d 1236, 1237 (5th Cir. 1976); Hatfield v. Commissioner, 68 T.C. 895, 898 (1977); Hicks v. Commissioner, T.C. Memo. 1992-649; Zegel v. Commissioner, T.C. Memo. 1989-522. Petitioner’s claim that he has no obligation to file a return or pay any tax is without merit, and we reject it. III. Petitioner’s Gain At issue is the amount of petitioner’s gain from the sale of the securities. At trial, petitioner conceded that, during 2000, his brokerage account at Solomon Smith Barney (Smith Barney) was credited with $225,390, the proceeds from sales of the securities. He claimed, however, that, the securities were sold at a net loss of $18,888 and, taking into account fees in the amount of $1,400 he paid Smith Barney, his total loss on the sales of the securities was more than $20,000. Petitioner determines that he suffered a net loss on the sales of the 1(...continued) threshold for which a return was required from an individual for 2000, no matter what the individual’s filing status (single, married filing jointly, etc.). See Instructions accompanying 2000 Form 1040, U.S. Individual Income Tax Return, p. 15.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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