N. Thomas Ryan - Page 4

                                        - 3 -                                         
               Some of the facts have been stipulated, and they are so                
          found.  The stipulation of facts, the stipulation of settled                
          issues, and the attached exhibits are incorporated by this                  
          reference.  Petitioner resided in Brooksville, Florida, at the              
          time the petition was filed.                                                
               At the time the notice of deficiency was issued, petitioner            
          had not filed Federal income tax returns for 1997, 1998, and                
          1999.  Respondent determined:  (1) That petitioner received wage            
          income for each tax year in issue; (2) that petitioner was                  
          entitled to a standard deduction for married filing separate                
          status; (3) that petitioner received income on the sale of                  
          certain securities in 1997 which is taxable as short-term capital           
          gain rates; and (4) that petitioner received nonemployee income             
          in 1997.                                                                    
               Petitioner does not dispute that he received wage income in            
          the amounts determined by respondent.  Petitioner does, however,            
          dispute the filing status, the characterization of capital gain             
          income, and a portion of the omitted nonemployee income.                    
          Immediately before trial, petitioner submitted penciled returns             
          for the years in issue in which he claimed the following losses             
          for a horse breeding activity:                                              











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