T.C. Memo. 2006-77
UNITED STATES TAX COURT
KENNETH DAVID PERRY AND LINDA RUTH PERRY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 619-04, 18226-04. Filed April 18, 2006.
Ps’ claimed net capital losses were disallowed to the
extent they exceeded $3,000, on authority of sec. 1211(b),
I.R.C. 1986.
Held: This limitation does not prevent the taxes
imposed by secs. 1 and 55, I.R.C. 1986, from being taxes on
income within the meaning of the Sixteenth Amendment to the
Constitution.
Kenneth David Perry and Linda Ruth Perry, pro sese.
Roger W. Bracken, for respondent.
MEMORANDUM OPINION
CHABOT, Judge: Respondent determined deficiencies in
individual income tax against petitioners in the amounts of
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011