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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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Last modified: November 10, 2007