Marc Kirch - Page 2




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               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.                                         









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