- 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: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