- 4 -
Petitioner complained on part V of Schedule C for 2003 that
the IRS has never given him a business loss, that the “mafia
lawyer” stole all he owned, and that he has fought with “them”
for 25 years.
Contrary to petitioner’s belief, he was apparently allowed a
business loss deduction of $10,000 for each year from 1982 to
2002. Under section 6212(a), if respondent determines that there
is a deficiency, he is authorized to issue to petitioner a notice
of deficiency. Respondent, however, did not issue to petitioner
a notice of deficiency or otherwise notify him that the
deductions claimed on the returns for 1982 to 2002 were
disallowed. See secs. 6212(a), 6320, 6330. Petitioner therefore
had the benefit of reducing his gross income by $10,000 for each
year from 1982 to 2002.
At trial, petitioner further complains that even though he
claimed a business loss on each and every return filed on and
after 1982, he was not granted an opportunity to appear before
the Court until the 2003 return was filed.
For the taxable year 2003, respondent finally disallowed the
business loss deduction of $10,000, determined a deficiency, and
issued to petitioner a notice of deficiency, often described as
the “ticket to the Tax Court”. Boyd v. Commissioner, 124 T.C.
296, 303 (2005), affd. 451 F.3d 8 (1st Cir. 2006); see sec.
6213(a).
Page: Previous 1 2 3 4 5 6 Next
Last modified: November 10, 2007