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Penalty
Petitioner(s) Year Deficiency I.R.C. Sec. 6662(a)
Shahrooz S. and 2000 $478,890 $95,778.00
Shida S. Jamie
Shahrooz S. Jamie 2001 137,839 27,567.80
Shahrooz S. Jamie 2002 200,138 40,027.60
The notice of deficiency for 2000 was addressed to both
Shahrooz S. Jamie (petitioner) and Shida S. Jamie, his wife
(Mrs. Jamie), and was based on a joint return that they filed for
that year. The notice of deficiency for 2001 and 2002 was
addressed only to petitioner. Respondent has agreed that
Mrs. Jamie is entitled to relief as an innocent spouse.
The issues for decision are:
(1) Whether petitioner is entitled and limited to a $3,000
per year deduction for capital losses from his trading activity
for 2000, 2001, and 2002;
(2) whether petitioner may claim net operating loss
carryovers in 2001 and 2002 with regard to losses sustained in
his transactions as a trader in securities in 2000 and 2001; and
(3) whether petitioner is liable for penalties under section
6662(a) of the Internal Revenue Code for substantial
understatements of income tax.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
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Last modified: May 25, 2011