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Respondent determined a deficiency in petitioner’s Federal
income tax of $25,964, an addition to tax of $5,562.22 pursuant
to section 6651(a)(1), an addition to tax of $3,090.12 pursuant
to section 6651(a)(2), and an addition to tax of $1,322.13
pursuant to section 6654(a) for the taxable year 2000.
After a concession1 by respondent, the issues for decision
are: (1) Whether petitioner was engaged in the trade or business
of trading securities; (2) whether petitioner may deduct for
taxable year 2000 a net operating loss (NOL) which purportedly
arose in taxable year 1999; (3) whether petitioner may exclude
any portion of his disability benefits from income for taxable
year 2000; and (4) whether petitioner is liable for additions to
tax pursuant to sections 6651(a)(1) and 6654(a) for taxable year
2000.
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. On the date the petition
was filed in this case, petitioner resided in North Potomac,
Maryland.
1In the notice of deficiency, as previously stated,
respondent determined petitioner was liable for an addition to
tax in the amount of $3,090.12 pursuant to sec. 6651(a)(2).
However, at trial, respondent conceded that petitioner was not
liable for the addition to tax under sec. 6651(a)(2).
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