Glenn S. Hodges - Page 6

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          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.                   





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