- 2 - All section references are to the Internal Revenue Code of 1986, as amended. All dollar amounts have been rounded to the nearest dollar. Some facts have been stipulated and are so found. The stipulation of facts, with attached exhibits, is incorporated herein by this reference. FINDINGS OF FACT Petitioner resided in Berkeley, California, at the time the petition was filed. During 1999 and 2000, petitioner worked full time as a facilities technician for Pacific Bell. On both his 1999 and 2000 Federal income tax returns, petitioner declared his occupation to be “facilities technician”. Beginning in 1998 and continuing through 2000, petitioner traded securities on his own account. He did not have any customers for his trading activity in 1999. Petitioner, a calendar year taxpayer, filed his 1999 Federal income tax return on July 6, 2001. He reported $28,160 in Form W-2, Wage and Tax Statement, income from Pacific Bell and a net short-term capital gain of $96,767 from his securities trading activity. He reported a tax liability of $32,246. He has paid only $3,447 of that liability. Respondent assessed the tax petitioner reported on the return, along with additions to tax for late filing and failure to pay.Page: Previous 1 2 3 4 5 6 7 NextLast modified: November 10, 2007