Hector Prowse, (2007)
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Hector Prowse, (2007)
PURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE.
T.C. Summary Opinion 2007-31UNITED STATES TAX COURT HECTOR PROWSE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 17121-05S. Filed March 1, 2007.Hector Prowse, pro se.Marc L. Caine, for respondent.COUVILLION, Special Trial Judge: This case was heard pursuant to section 7463 in effect when the petition was filed.1 The decision to be entered is not reviewable by any other court, and this opinion should not be cited as authority.Respondent determined deficiencies of $3,175.85 and $3,554, respectively, in petitioner's Federal income taxes for the years 2002 and 2003, an addition to tax under section 6651(a)(1) for the year 2002 in the amount of $511.71, an additional tax under section 72(t) in the amount of $107.85 for the year 2002, a liability of $2,505 for self-employment tax under section 1401(a) for the year 2003, and a negligence penalty under section 6662(a) for both years.In a trial memorandum, respondent notes that, prior to trial, respondent conceded a capital gain loss of $9,405 for the year 2002 that had been disallowed in the notice of deficiency, and, therefore, petitioner is entitled to a capital loss deduction of $3,000 for 2002 and a carryover capital loss deduction of $3,000 to 2003. As a result of this concession, the deficiencies, the addition to tax, and the penalties were r...See the full content of this document
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