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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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