- 2 -
Respondent determined a deficiency of $5,259 in petitioner’s
2000 Federal income tax, and additions to tax of $232.87 and
$119.02 pursuant to section 6651(a)(1) and (2), respectively.
After concessions1, there are three issues for decision: (1)
Whether petitioner is entitled to a deduction stemming from a
brokerage account he held with Kristian Capital Management, Inc.;
(2) whether petitioner is entitled to a deduction stemming from
his employment with Howard Systems, Inc.; and (3) whether
petitioner is liable for an addition to tax pursuant to section
6651(a)(1).
Background
The evidence in this case consists of oral stipulations
agreed upon at trial and documented evidence received at trial.2
The stipulation of facts and the attached exhibits are
incorporated herein by reference.
At the time the petition was filed, petitioner resided in
Upper Darby, Pennsylvania.
1 Respondent has conceded the issue as to addition to tax
pursuant to sec. 6651(a)(2).
2 Respondent contacted petitioner no less than nine times
between March 1, 2004, and November 1, 2005, each time requesting
that petitioner stipulate the facts of the case. When no
stipulation of facts was agreed upon by the date of the trial,
the Court took oral stipulations from the parties and received
into evidence documentation that detailed the parties’
agreements.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011