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Petitioner also filed his 2000 Federal income tax return on
July 6, 2001. He reported, among other things, a net short-term
capital loss of $129,436 from his trading activity.
Petitioner did not submit to the Internal Revenue Service
(IRS) or attach to his 1999 return an IRS Form 3115, Application
for Change in Accounting Method, making an election under section
475(f) to use the mark-to-market method of accounting.
Petitioner did not submit to the IRS or attach to his 2000
return an IRS Form 3115 making an election under section 475(f)
to use the mark-to-market method of accounting.
On or about February 23, 2006, petitioner attempted to file
IRS Forms 1040-X, Amended U.S. Individual Income Tax Return, for
1999 and 2000. Petitioner’s purpose in attempting to file
amended returns was to carry back a net operating loss claimed in
2000 to offset the net short-term capital gain reported for 1999.
Respondent did not allow petitioner’s amended returns.
On November 6, 2004, respondent issued a Collection Due
Process Notice to petitioner concerning his 1999 tax liability,
and on December 6, 2004, petitioner filed an IRS Form 12153,
Request for a Collection Due Process Hearing. On February 23,
2006, respondent conducted a collection due process hearing for
petitioner. During the course of that hearing, petitioner
submitted the Forms 1040-X to the Appeals settlement officer
conducting the hearing for transmission to the appropriate IRS
office. Petitioner did not raise any collection alternative
during the hearing.
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Last modified: November 10, 2007